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  • Comment Detail

  • Date: 07/15/24
    First Name: Tim
    Last Name: Sullivan
    Email: t.sullivan@globalcu.org
    Organization Type: organization
    Organization: Alaska Credit Union League

  • Comment

    The Honorable Sandra L. Thompson
    Director
    Federal Housing Finance Agency
    Constitution Center
    400 7th Street, SW
    Washington, D.C. 20219

    The Alaska Credit Union League (ACUL) represents ten credit unions doing business in Alaska including all nine Alaska based credit unions and their more than 500,000 members who reside in Alaska. ACUL has concerns regarding an incentive system that may be developed as proposed in the Federal Housing Finance Agency’s request for input soliciting comments on “the mission of the Federal Home Loan Bank System as the FHFA considers next steps for related rulemakings."

    For more than 90 years, the Federal Home Loan Bank System (System) has served as a reliable and critical source of funding to America’s credit unions and has provided important financial stability to the broader financial system. The System works well and has proven so repeatedly.

    Federal Home Loan Bank (FHLB) liquidity is critically important to Alaska’s credit unions. The FHLB Competitive Affordable Housing Program has provided $28 million in grants for 2,393 Alaskan homes and the FHLB Down Payment Products have provided $6 million in grants for 908 Alaskan homes. Additionally, FHLB has provided Alaska credit unions with $294 million in advances and $19 million in mortgage programs granting us the financial stability to access liquidity through all economic cycles.

    Congress created the System and its mission, any changes to the System’s mission should be determined by Congress, not FHFA. What Congress has specifically required and authorized is outlined in the Federal Home Loan Bank Act, which is to provide liquidity to members in support of housing and community development. Further, Congress has authorized the types of institutions eligible for membership and the requirements for them to access liquidity and other products and services.

    This RFI contemplates an incentive system with membership categories or tiers where access is different for different types of members. Congress did not authorize this nor did they intend to restrict access or discriminate against any member. All FHLB members have a strong and demonstrable connection to the System’s mission as Congress intended, and they should continue to have the same access to FHLB liquidity, on equal terms. We urge the FHFA to ensure that all current members continue to have the same access to it as they do today.

    Thank you,

    Tim Sullivan, President
    Alaska Credit Union League

    cc: Senator Lisa Murkowski
    Senator Dan Sullivan
    Congresswoman Mary Peltola