Letter to the Federal Reserve About the Critically Important Role of FHLBs

ICBA submitted a second comment letter in response to the Federal Reserve’s request for information on the discount window.

ICBA touted the critical importance of the Federal Home Loan Banks as a source of liquidity for community banks and said it opposes any efforts to devalue FHLB liquidity or steer banks away from FHLB advances, particularly by their prudential regulator. 

Further, ICBA encouraged efforts to fix existing operational challenges with the discount window and solve overlapping security interests that could delay access to emergency funding.