January 7, 2015
CBAI submitted a comment letter to the Federal Housing Finance Agency (“FHFA”) concerning its harmful proposed changes to Federal Home Loan Bank (“FHLB”) membership rules. These proposed changes will have a profound impact on the FHLB System, FHLBanks and FHLB Members, by imposing ongoing requirements that all FHLB Members would need to meet in order to maintain their membership.
The impact of the Proposed Rule include: increased regulatory burden on community banks and thrifts; difficulty in Member balance sheet management; the stability of the System and its continued reliability as a funding partner, particularly in times of economic stress; uncertainty about continuing Member access to liquidity; the future value of FHLBank membership; and the impacts on housing and community development throughout the System.
CBAI previously raised concerns about the FHFA’s 2010 Advanced Notice of Proposed Rulemaking (“ANPR”) on this subject and CBAI has again called on the FHFA to formally withdraw the harmful Proposed Rule. Read CBAI’s Comment Letter.