From: Witty Allen
Sent: Monday, November 03, 2008 5:53 PM
To: pmitchell@harriscaddell.com

Subject: RIN # 3064-AD37 Re: FDIC Insurance Coverage for Attorney's IOLTA Accounts

On principle I have always opposed IOLTA accounts.   We as a Bar Association have by administrative court rule created a private slush fund out of our client's interest (I recognize it as legal and unavoidable).   I believe it would be better for banks to recognize more profit from a trust account which does not pay interest than for interest which is economically unproductive to be computed to be paid over to others whose objectives or purposes may not be consistent with my client's.    

J. Witty Allen
Attorney
NOWLIN & ASSOCIATES, LLC
118 East Moulton Street
P.O. Box 1149
Decatur, Alabama 35602