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  • Comment Detail

  • Date: 07/15/24
    First Name: Danna
    Last Name: Burchess
    Email: dburchess@fnbgillette.com
    Organization Type: individual
    Organization: First National Bank of Gillette

  • Comment

    Danna R. Burchess
    824 Rodeo St
    Gillette WY 82718
    dburchess@fnbgillette.com
    (308) 379-7679
    July 15, 2024

    Federal Housing Finance Agency
    Office of the Director
    400 7th Street, SW
    Washington, D.C. 20219

    Dear FHFA,
    I am writing to provide feedback on the Request for Input (RFI) regarding the mission of the Federal Home Loan Banks (FHLBanks), as issued by the FHFA. This response addresses the three main sections outlined in the RFI.

    Mission Section:

    The statutory mission of the FHLBanks is clearly defined in the Federal Home Loan Bank Act, encompassing the provision of liquidity to members and the support of affordable housing and community development. It is essential to recognize that this mission has been faithfully upheld throughout the history of the FHLBanks. They consistently provide stable liquidity through advances and letters of credit, which are underpinned by collateral pledged by members. Moreover, the FHLBanks facilitate affordable housing initiatives through direct mortgage purchases and voluntary programs tailored to regional needs.
    While the FHFA has a role in assessing how effectively the FHLBanks fulfill their mission in terms of safety and soundness, any adjustments to the mission itself fall within the purview of Congress. Therefore, it is crucial that the FHFA’s regulatory oversight remains focused on evaluating performance rather than altering the mission mandate.

    Measurement Section:

    All activities undertaken by the FHLBanks inherently contribute to fulfilling their mission since they operate strictly within the boundaries set by Congress. Therefore, every liquidity provision, affordable housing initiative, and community investment effort should be recognized as mission-centric activities. The regulatory framework already in place comprehensively monitors and ensures that these activities adhere to established standards of mission achievement.

    Member Incentives Section:

    Fair and equitable treatment of all members is mandated by the FHLBank Act, ensuring impartiality and considering the creditworthiness and safety of members. It is crucial that incentives provided to members align with statutory requirements and promote broad access to FHLBank resources without creating disparities among members based on the types or levels of housing assets on their balance sheets.
    Congress has already authorized incentives such as the broader collateral eligibility for community financial institutions and discounted advances through programs like Community Investment Cash Advance (CICA) and Community Investment Program (CIP). These incentives are pivotal in encouraging member participation in FHLBank initiatives aimed at promoting affordable housing and community development.
    In conclusion, the FHFA’s oversight should continue to support the FHLBanks in fulfilling their statutory mission effectively and efficiently. This includes maintaining a regulatory approach that ensures accountability and transparency while respecting the statutory boundaries that define the FHLBanks’ mission.
    Thank you for considering these comments as part of the RFI process. I look forward to seeing how the FHFA incorporates stakeholder input into its ongoing efforts to strengthen the role of the FHLBanks in the housing finance system.
    Sincerely,

    Danna R. Burchess
    Executive Vice President/ Chief Financial Officer
    First National Bank of Gillette