Federal Deposit
Insurance Corporation

Subject: Interagency Guidance on Nontraditional Mortgage Products - FR Citation Date 12/2

Dear Sirs: As an "over 50 year" banker I would like to state that it has always been our bank's goal to get people out of debt. This philosophy has served us well and the bank is now 103 years old. The use of a reverse mortgage where a check is sent to the borrower every month seems contrary to that philosophy. I think, however, it has merit when an individual (most generally a widow) wishes to maintain a home but also needs to utilize the equity that has been built up over many years. As always there will be some "bad apples" who will missinterpret this type of financing but that has always been the case and we have protection in place for this type of lending. Our bank has not yet promoted this type of loan but I see examples of where it is most appropriate.

In regard to Interest Only lending, that also has a place in order to help out an individual or business TEMPORARILY when adverse situations exist. We have even used NO interest on a portion of the credit as a means of helping to return to a profitable status. Not the way we want to do business but I can document where it has helped prevent bankruptcy where everyone loses.

Thank you for your interest in this issue.

Alice M. Dittman, Chairman
Cornhusker Bank, Lincoln, NE