Federal Deposit
Insurance Corporation

From: Marty Noll [mailto:MartyN@cboprf.com]
Sent: Wednesday, October 29, 2008 12:48 PM
To: Comments
Subject: RIN 3064-AD37

Please reconsider the cost of the guarantee of interbank, unsecured borrowings. 75bps is high relative to the fed funds target rate and the rate at which funds are actually trading. In different terms, unless indexed or readjusted, the cost of the guarantee could be greater than the value of the funds guaranteed. MJNoll