65 Federal Register 26518, May 8, 2000. The American Bankers Association brings together all categories of banking institutions to best represent the interests of the rapidly changing industry.
Many community banks face serious funding shortages.
The liquidity provided by the Federal Home Loan Banks through advances has already become a vital source of funds for these institutions. It is expected that the expanded categories of collateral will greatly enhance member institutions ability to use advances to meet the credit needs of their communities. For that reason, ABA is pleased that the Finance Board has developed a thoughtful and well-reasoned proposed rule in a relatively short time frame. However, ABA does believe that the rule can be improved in several areas. Our comments below reflect these views.