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FDIC Federal Register Citations
From: Charlie Saeman
From: Charlie Saeman, President & CEO,
We appreciate the opportunity to comment on the TLGP plan.
We are very concerned that banks who do not participate in the program will suffer the unintended consequence of being either shut out of Fed Fund borrowings or if borrowings are available from correspondents there will likely be a substantial premium. Our own situation complicates the matter further. We did not have unsecured borrowings as of September 30, 2008 and therefore we would have to apply for coverage. We donít know what kind of future borrowings we might need. Historically, we do need a modest level of borrowings in the first 4 months of the year. We donít know if it will be necessary to be part of the program or not to support seasonal needs.
Moreover, the 75 bp seems to be an excessive premium especially for short term (overnight) borrowings.
Our concern is that the TLGP program could in fact limit our liquidity where we have never had issues with liquidity before.
Thank you for your consideration of our concerns.
|Last Updated 11/12/2008||Regs@fdic.gov|