This includes opposition to any compromise that would grant the use of membership fees in conjunction with stock investments. Opposition to Cap on Capital . Initial indications suggest that the FHFB is willing to reconsider the need for a limit on the amount of capital that a FHLBank may raise. ABA urges the FHFB to remove the proposed hard cap on capital. If the hard cap is eliminated, there is no need for membership fees to manage capital growth.
ABA strongly supports removal of the hard cap along with elimination of membership fees.
It is also important to modify the proposal in the final rule to permit explicitly the issuance of only Class B stock. As the FHFB has heard from a number of sources, several FHLBanks intend to issue only Class B stock. An all-Class B stock achieves the goal of more permanent capital for the FHLBank System. To the extent that the FHFB has issued contrary advice or opinions, ABA urges the FHFB to rescind those positions. Redemption Clarification .