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ACTION ALERT – Urge FHFA to Withdraw Proposed Restrictive FHLB Membership Rules

Earlier this fall, the Federal Housing Finance Agency (“FHFA”) released 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.

These impacts include but are not limited to: increased regulatory burden and difficulties 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 impact on housing and community development throughout the System.

The FHFA has requested comments on its proposed rule by Monday, January 12, 2015. CBAI will be commenting on the proposed rules and encourages CBAI/FHLB- Chicago members to make their voices heard by submitting comment letters to the FHFA by the January 12th deadline.

Sample comment letters have been included for your convenience. The appropriate letter will depend on whether your bank has assets of less than $1.108 billion (letter #1) or assets above $1.108 billion (letter #2); for thrifts the appropriate letter will depend on whether the thrift became a FHLB member before 1-1-1989 (letter #1) or after 1-1-1989 (letter #2).

Please take a few minutes to personalize the attached draft comment letter and submit comments to the FHFA following these instructions.

Please note it is critical to reference the regulatory information number (RIN 2590-AA39). Submit comment letters via the Federal eRulemaking Portal at http://www.regulations.gov. Enter RIN 2590-AA39 in the Search area, and then follow the instructions for submitting comments.

When submitting comment letters to the Federal eRulemaking Portal, please email the comments directly to the FHFA at REGCOMMENTS@FHFA.GOV, including the RIN 2590-AA39 in the subject line of the email. For example - Subject: Name of your institution comments re: RIN2590-AA39. A PDF format is recommended. 

David G. Schroeder
Vice President Federal Governmental Relations