Comments are In

Friday, July 19, 2024— That was fast! 

Results are in – too early to opine, so today I’ll just summarize.

In a nutshell, the Request for Input on Mission of the FHLBs (* aggressively abbreviated):

Regulator (FHFA) to Regulated Entity (FHLBanks): 

After an extensive almost 2-year endeavor designed to think about ways to make the FHLBanks more responsive to the changing financial landscape, we have compelling evidence the FHLBanks can and should do more to support housing and community development.  Can you please provide input into how this can be achieved?

FHLBanks to Regulator:

It is perfectly clear how we are supposed to act (though we choose to default to how we are required to act), and we do it perfectly – on all fronts.

Everything we do is finely orchestrated to maximize our effectiveness in fulfilling the mission and any prospective changes risk dismantling all the good we do.

Attempting to develop a system to allocate funds most effectively is probably beyond your authority.

The recent SCOTUS ruling will make it impossible to enact regulatory changes to that which you are asking for input.

AND we’d love to work with you on this project.

Wow!

More reading to do, and opinions to be formed, I hope I’m allowed.

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