Comment Detail
Date: 07/15/24 First Name: Susan Last Name: Savat Email: smsavat@merchantsbank.com Organization Type: organization Organization: Merchants Financial Group/Merchants Bank Comment
Good morning, I would like to comment regarding the proposed changes to the FHLB system mission and activities regarding supporting affordable housing. As the CFO of Merchants Financial Group, we have found the mission of the FHLBs to be clear and do not feel it needs to be changed or clarified beyond what was outlined in statute. The FHLB is critical to our organization and provides significant support for affordable housing as well as stability and liquidity in the banking system. Adding additional metrics and thresholds or incentives for only certain activities will only raise costs or restrict access unnecessarily and will reduce availability of mortgage credit and community development funding which we believe to be harmful to affordable housing activities. No change is needed, please do not go looking to fix something that is not broken.
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