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  • Comment Detail

  • Date: 07/15/24
    First Name: Larry
    Last Name: Thompson
    Email: lthompson@firstmontanabank.com
    Organization Type: N/A
    Organization: First Montana Bank

  • Comment

    Federal Housing Finance Agency - First Montana Bank has been an FHLB member for around 30 years or so, dating back to the days of the FHLB Seattle. The FHLB is and has always been a very important source of liquidity for our bank on a day-to-day basis, as well as providing the primary source of liquidity in our contingency liquidity plan.
    The FHLB's mission was established by Congress, and Congress also has authorized the types of institutions eligible for membership and the products and services for which members are eligible.
    I feel that the FHFA changing the FHLB's mission statement, creating metrics and thresholds to evaluate mission achievement, and/or creating other guidelines which if implemented could restrict access to a member's liquidity would be regulatory overreach. These types of changes should only be made by Congress. Also, these types of changes could easily create an unintended negative impact which could seriously affect housing financing and harm the people the FHFA is intending to project.
    Sincerely
    Larry Thompson
    EVP & CFO
    First Montana Bank, Inc.
    Missoula, Mt