We have been advising clients for some time of proposals that exacerbate strategic pressure on the Home Loan Banks.  One of these now finalized is the FDIC’s approach to deposit-insurance assessments.  As anticipated, it takes a big whack out of incentives for banks – especially large ones – to use the FHLBs.  This of course comes when the Administration, as discussed on Friday, is also seeking ways to cut FHLB advances back big-time.

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