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Missouri FHLB Comment Letter, Senate Concerns

The Missouri Credit Union Association (MCUA) is voicing concerns with the Federal Housing Finance Agency (FHFA) on behalf of Missouri's credit unions in response to proposed amendments to the Federal Home Loan Bank (FHLB) membership criteria. Click here to read MCUA's comment letter. There is still time for credit unions in Missouri to also weigh in on the proposal, with comments due by January 12.

The FHFA proposal would require FHLB members and those applying to be members to retain 1% of assets in home mortgage loans and 10% in residential mortgage loans on an ongoing basis. Currently, the 10% requirement only applies when an applicant first seeks membership in an FHLB. Under the proposal, community banks with less than $1 billion in average total assets (adjusted annually for inflation) are exempt.

"This has the potential to have a significant, detrimental impact on credit unions in the state," says John Thomas, senior vice president of regulatory compliance. "It is very important for credit unions to have access to liquidity, and the FHLB is a primary source for many."

The effort is also getting support from Missouri U.S. Senator Roy Blunt (R), who is one of 27 U.S. Senators who signed a letter to the director of the Federal Housing Finance Agency (FHFA), urging the agency to reconsider proposed amendments to the FHLB membership criteria. Members of Congress are urging the FHFA director to bring the issue to Congress for policy change decisions.

The agency extended its initial comment period with letters due by January 12. Submit a comment letter on the FHFA website here -

Approximately 19% of federally insured credit unions are FHLB members.

Questions? Please contact MCUA's Compliance department via email or phone, 800.446.3620.