Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW,
Washington, DC 20429

SUBJECT: Advertisement of Membership

Dear Mr. Feldman:

Thank you for the opportunity to comment on the Proposed Rule issued on July 17, 2006 on ‘Advertisement of Membership’. Please consider the following comments;

• Advertising for non-deposit products (NDPs) or hybrid products that offer both NDP and deposit-related products or services - This is generally a matter of uncertainty for compliance officers and needs clarification. Our Marketing Department frequently includes all the services that are offered by our trust department, investments, and insurance agency in one advertisement with traditional bank products... It is sometimes challenging to comply with the FDIC regulation and the Interagency Policy Statement on Retail Sales of Nondeposit Investment Products for one advertisement containing both of these components. I recommend that the official advertising statement be plainly clarified for these two regulations.

• Section 18(a)(1)(A) of the FDI Act states that each insured depository institution shall display, at each place of business maintained by that institution, a sign or signs relating to the insurance of the deposits. Section 328 could be modified to require the official sign to be displayed at each bank entrance accessible to customers as opposed to each station or window where insured deposits are usually and normally received.

• It is understood that institutions will be allowed to order as many signs as needed to comply with the final regulation at no cost to the financial institution. This, however, is a cost to taxpayers in general, for a change that could be considered without substantive difference. Perhaps a ‘grandfathering’ approach would be in order to allow current signage to remain in compliance until replaced, etc.

Thank you for your consideration of these comments under the ‘Notice of Proposed Rulemaking for Advertisement of Membership’.

Respectfully,

Jeanette L. Wampler
VP & Compliance Officer
First United Bank & Trust