FDIC Federal Register Citations

Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW.
Washington, DC 20429                            (via e-mail to: comments@FDIC.gov)

Re: Deposit Insurance Regulations; Living Trust Accounts

Dear Sir:

Jackson Federal Bank (the “Bank”) is an OTS-chartered savings bank with $1.7 billion in assets located in Brea, California. We operate 15 retail offices in southern California. We have approximately 57,000 deposit accounts representing 34,000 households.

We appreciate the opportunity to comment on the proposed changes to the FDIC insurance coverage, since this is an important issue to our customers. We believe that consumer interests are best served when FDIC insurance coverage is easily understandable. Consumers have been educated by the industry on how to structure accounts to provide maximum insurance coverage, and most consumers do this by structuring the vesting on deposit accounts with qualifying beneficiaries. The current insurance rules for living trusts conflict with this standard, therefore, consumers who chose to use a living trust as an estate management tool do not have access to the same insurance coverage that they would receive if they maintained those accounts outside of the living trust.

We believe that the FDIC insurance coverage rules should be changed so that accounts vested as living trusts with qualifying beneficiaries receive the same treatment that accounts held outside of a living trust receive when those accounts have qualifying beneficiaries.

Sincerely,

Carol Snodgress
Senior Vice President
Retail Banking
Jackson Federal Bank
Brea, CA