Senators Ask FHFA to Revisit FHLBank Membership Requirements

On December 18, DS News published an article discussing a signed letter by U.S. Senators to Federal Housing Finance Agency (FHFA) Director Mel Watt concerning stricter membership requirements for Federal Home Loan Banks.

Senators Ask FHFA to Revisit FHLBank Membership Requirements

Twenty-seven senators have signed a letter addressed to Federal Housing Finance Agency (FHFA) Director Mel Watt asking him to reconsider the stricter membership requirements for the Federal Home Loan Banks the Agency proposed in September.

The changes to membership requirements outlined by Watt in a speech at the FHLBank Director’s Conference on September 2 require members to hold 1 percent of their assets in home mortgage loans (HML) on an ongoing basis, whereas the previous rule requires members to demonstrate this only at the time of their application and not at any time afterward. Another proposed change requires members to adhere to the 10 percent residential mortgage loan (RML) requirement on an ongoing basis as opposed to just at the time of application.

The senators’ letter, dated December 15 and co-authored by Senators Joe Manchin (D-West Virginia) and Mark Kirk (R-Illinois), states that “(t)he proposed rule affects long-standing membership rules for the Federal Home Loan Bank system and will negatively affect new and current members in the system.” Twenty-five other senators signed the letter.

“Under the current regulations, if a member does not have assets that meet the system’s statutory and regulatory requirements for eligible collateral, it cannot borrow,” Manchin and Kirk wrote in the letter. “Under the proposed regulation, however, even if a member has assets that meet this test, a member could be expelled from membership if the member cannot meet the new – and unprecedented – mortgage asset tests for continued membership. The consequences are harsh and the terms of the proposed rule are inconsistent with the explicit terms of the FHLBank Act.”

The letter states that in the 80 years since it was created, the FHLBank system has been a key partner in the success of smaller institutions, and the authors pointed out that Watt has stated the importance of these institutions in housing finance. The authors of the letter also pointed out the value of the cooperative FHLBank model was demonstrated by the stability the FHLBanks provided during the 2008 financial crisis.

“Given their success and importance, we are concerned the proposed rule could jeopardize the ability of FHLBanks to provide liquidity to community financial institutions when they need it most,” the letter said.

Manchin and Kirk also asked Watt in the letter to “consult further with other agencies before finalizing any rule that affects these much needed financial institutions,” since the FHLBank system is currently operating “safely and successfully.”

“In light of these concerns, we urge you to reconsider this proposal and consult with Congress, which is where these important policy decisions should be made,” the letter said.

The senators who signed the letter were (alphabetically): Ayotte (R-New Hampshire), Baldwin (D-Wisconsin), Blunt (R-Missouri), Cardin (D-Maryland), Chambliss (R-Georgia), Coburn (R-Oklahoma), Cochran (R-Mississippi), Coats (R-Indiana), Donnelly (D-Indiana), Fischer (R-Nebraska), Hirono (D-Hawaii), Hoeven (R-North Dakota), Inhofe (R-Oklahoma), Isakson (R-Georgia), Ron Johnson (R-Wisconsin), Johanns (R-Nebraska), King (I-Maine), Kirk (R-Illinois), Manchin (D-West Virginia), Moran (R-Kansas), Portman (R-Ohio), Roberts (R-Kanas), Rubio (R-Florida), Scott (R-South Carolina), Tester (D-Montana), Thune (R-South Dakota), and Wicker (R-Mississippi).

Last month, a bipartisan group of 68 house members signed a letter to Watt, authored by Spencer Bachus (R-Alabama) and David Scott (D-Georgia), expressing the same sentiments regarding the proposed FHLBank membership rule. The National Association of Federal Credit Unions (NAFCU) voiced similar concerns in November.

Please click here to view the article online.

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

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CEO

Alan Jaffa

Alan Jaffa is the Chief Executive Officer for Safeguard Properties, steering the company as the mortgage field services industry leader. He also serves on the board of advisors for SCG Partners, a middle-market private equity fund focused on diversifying and expanding Safeguard Properties’ business model into complimentary markets.

Alan joined Safeguard in 1995, learning the business from the ground up. He was promoted to Chief Operating Officer in 2002, and was named CEO in May 2010. His hands-on experience has given him unique insights as a leader to innovate, improve and strengthen Safeguard’s processes to assure that the company adheres to the highest standards of quality and customer service.

Under Alan’s leadership, Safeguard has grown significantly with strategies that have included new and expanded services, technology investments that deliver higher quality and greater efficiency to clients, and strategic acquisitions. He takes a team approach to process improvement, involving staff at all levels of the organization to address issues, brainstorm solutions, and identify new and better ways to serve clients.

In 2008, Alan was recognized by Crain’s Cleveland Business in its annual “40-Under-40” profile of young leaders. He also was named a NEO Ernst & Young Entrepreneur Of The Year® Award finalist in 2013.

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Esq., General Counsel and EVP

Linda Erkkila

Linda Erkkila is the General Counsel and Executive Vice President for Safeguard Properties, with oversight of legal, human resources, training, and compliance. Linda’s broad scope of oversight covers regulatory issues that impact Safeguard’s operations, risk mitigation, strategic planning, human resources and training initiatives, compliance, insurance, litigation and claims management, and counsel related to mergers, acquisition and joint ventures.

Linda assures that Safeguard’s strategic initiatives align with its resources, leverage opportunities across the company, and contemplate compliance mandates. She has practiced law for 25 years and her experience, both as outside and in-house counsel, covers a wide range of corporate matters, including regulatory disclosure, corporate governance compliance, risk assessment, compensation and benefits, litigation management, and mergers and acquisitions.

Linda earned her JD at Cleveland-Marshall College of Law. She holds a degree in economics from Miami University and an MBA. Linda was previously named as both a “Woman of Influence” by HousingWire and as a “Leading Lady” by MReport.

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COO

Michael Greenbaum

Michael Greenbaum is the Chief Operating Officer of Safeguard Properties, where he has played a pivotal role since joining the company in July 2010. Initially brought on as Vice President of REO, Mike’s exceptional leadership and strategic vision quickly propelled him to Vice President of Operations in 2013, and ultimately to COO in 2015. Over his 14-year tenure at Safeguard, Mike has been instrumental in driving change and fostering innovation within the Property Preservation sector, consistently delivering excellence and becoming a trusted partner to clients and investors.

A distinguished graduate of the United States Military Academy at West Point, Mike earned a degree in Quantitative Economics. Following his graduation, he served in the U.S. Army’s Ordnance Branch, where he specialized in supply chain management. Before his tenure at Safeguard, Mike honed his expertise by managing global supply chains for 13 years, leveraging his military and civilian experience to lead with precision and efficacy.

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CFO

Joe Iafigliola

Joe Iafigliola is the Chief Financial Officer for Safeguard Properties. Joe is responsible for the Control, Quality Assurance, Business Development, Marketing, Accounting, and Information Security departments. At the core of his responsibilities is the drive to ensure that Safeguard’s focus remains rooted in Customer Service = Resolution. Through his executive leadership role, he actively supports SGPNOW.com, an on-demand service geared towards real estate and property management professionals as well as individual home owners in need of inspection and property preservation services. Joe is also an integral force behind Compliance Connections, a branch of Safeguard Properties that allows code enforcement professionals to report violations at properties that can then be addressed by the Safeguard vendor network. Compliance Connections also researches and shares vacant property ordinance information with Safeguard clients.

Joe has an MBA from The Weatherhead School of Management at Case Western Reserve University, is a Certified Management Accountant (CMA), and holds a bachelor’s degree from The Ohio State University’s Honors Accounting program.

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Business Development

Carrie Tackett

Business Development Safeguard Properties