Comment Detail

Comment

Gateway Bank is a locally owed community bank supporting small businesses and consumers in our area.

• The FHLB System is a reliable and stable funding source for community banks and supports lending
activity in housing, small business and community development and it has proven to be this
source during all economic cycles. Any changes that adversely impact the reliability and
stability of funding will adversely impact access to credit for consumers and small businesses.
• The mission of the FHLB System was established by Congress and is outlined clearly in the
Federal Home Loan Bank Act. Therefore, any changes to the mission should be directed by
Congress.
• Congress also identified the types of institutions eligible for membership and the requirements
that must be met for those institutions to access liquidity and other products and services. Any
changes to membership eligibility should be directed by Congress.
• Similarly, Congress did not authorize a system where access is different for different types of
members. All members have a strong and demonstrable connection to the System’s mission as
Congress intended, and they should continue to have the same access.

For over 90 years, the Federal Home Loan Bank System has served as a reliable and critical source of
funding for community banks. The System works well and has proven so repeatedly. As you consider
changes to the mission, please do no harm to community banks.

Sincerely,

Bruce J. Downey
President
Gateway Bank