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FDIC Federal Register Citations Southern Missouri Bank & Trust From: Matt Funke [mailto:mfunke@smbtonline.com] May 25, 2006 VIA E-MAIL Dear Mr. Feldman, I am writing to provide comment regarding proposed rules allocating the one-time assessment credits authorized under the Deposit Insurance Reform Act of 2005 on behalf of Southern Missouri Bank & Trust, a community bank headquartered in Poplar Bluff, Missouri. We understand the need to begin replenishments of the Deposit Insurance Fund, and applaud the actions of Congress to recognize that institutions which have previously paid insurance premiums ought to receive credit for those payments. Additionally, we understand the reasoning behind the FDICs decision to interpret the undefined term successor to include mergers and consolidations, but to exclude purchasers of deposits (e.g., branch sales). As an institution with both branch sales and purchases since 1996, we stand to sustain little impact from the decision, but it is our opinion, nevertheless, that the proper measurement would follow the deposits, rather than the charter. While this would mean some additional work in tracking deposit sales, we believe that the deposits which generated the premiums paid are a truer measure of to whom credit is due than simple charter transfers. Southern Missouri Bank appreciates the opportunity to comment on this
matter and the consideration we know will be given our thoughts on it. Sincerely,
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Last Updated 05/30/2006 | Regs@fdic.gov |