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TLGP, on the surface, appear to offer the banking industry much needed relief. However, community banks with no unsecured debt at September 30, 2008 are being forced to a: negotiate with their primary regulator (FDIC) for some level of coverage through an undefined formula in order to have any coverage at all; and b: "opt in" (even though this happens through no action) in order to access the Fed Funds market at market rates. These same community banks, at least this one, were not responsible for the economic chaos currently in evidence.
Between these proposals and other proposed changes to insurance assessments, we now face quarterly assessments in excess of $100,000. While it is part of our duty as bankers, draining the capital of well-run community banks to prop up poorly run mega-banks can't be the right answer. Please reconsider what you ask of us and extend the deadline for the "opt out" decision at least until all the facts are known.
Ed Wrabetz, VP & CFO
|Last Updated 11/12/2008||Regs@fdic.gov|