Federal Deposit
Insurance Corporation

From: Jack Myles
Sent: Tuesday, November 04, 2008 11:53 AM
To: Comments
Subject: Assessments - RIN-3064-AD35

The addition of a new financial measure, the adjusted brokered deposit ratio, would negatively impact community banks.  Deposits generated from a listing service are not significantly different than Certificates of Deposit generated from any advertising source such as newspaper ads.  Additionally, listing services create a market place whereby smaller institutions create liquidity.  Based on the enormity of the current bail out and liquidity programs being put forward by the government, hurting a proven source of liquidity for small banks seem ill timed at best.

Jack Myles
Pres. & CEO
North County Bank