From: Michael Hobbs
Sent: Thursday, November 06, 2008 12:04 PM
To: Comments
Subject: Assessments - RIN-3064-AD35 

It’s simple really; if brokered deposits are managed accordingly they provide a safe alternative funding source.  It gets back to managing the balance sheet.  Please realize that because of “free enterprise” and deregulation w/n the industry that bank’s funding sources have extended beyond the collection of deposits from w/n communities they serve.  Too many banks, insurance companies, investment companies, etc. fighting for the same dollar…..rates increase beyond reason…simply supply v. demand.  Alternative sources are necessary and therefore banks should not be penalized for using them correctly.    

Michael B. Hobbs
First Commercial Bank CEO