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  • Comment Detail

  • Date: 07/13/24
    First Name: Brad
    Last Name: Bolton
    Email: bbolton@communityspirit.bank
    Organization Type: organization
    Organization: Community Spirit Bank

  • Comment

    The mission of the FHLBs is clear and does not need to be changed or clarified beyond what was outlined in statute.
    FHFA should “Do No Harm” to negatively affect the relationship between the FHLB System and community banks who depend on the system for liquidity and contingency funding.
    The FHLB system should continue to be a collateral based system and not credit based and should avoid any “unusual transaction testing” for community banks seeking to obtain advances.
    Profits from the system should continue to be returned to AHP programs and community bank shareholders.
    The FHLB System has successfully carried out both aspects of its mission—to provide liquidity to members and to provide affordable housing and community development—in a safe and sound manner through all economic cycles.

    Creating additional requirements that raise the cost or restrict FHLB advances to members in good standing with eligible collateral will only reduce the availability of mortgage credit or community development funding.

    Please leave the FHLB systems to act and operate independently and “do not harm to them”.