FDIC Federal Register Citations

Mr. Robert E. Feldman,
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Dear Mr. Feldman:

I am writing to comment on the proposed rules to amend the deposit insurance regulations for living trust accounts. I am Vice President and Compliance Officer of The First National Bank of Mount Dora, a small independent national bank, with assets of $124 million, located in central Florida.

Adoption of Alternative Two, which would provide up to $100,000 separate coverage for each owner of the trust, would simplify the deposit insurance rules for living trusts and make the rules easier to understand by the customer and bank personnel. It would eliminate additional recordkeeping requirements for the bank that would be required by Alternative One. In addition, customers would have the option to open POD accounts that would be eligible for separate per-beneficiary POD coverage.

Though Alternative One would, in some instances, provide more insurance coverage for the living trust account, the rules for this proposal are more cumbersome and difficult to understand and place a greater burden of recordkeeping on banks.

I recommend adoption of Alternative Two.

Thank you for the opportunity to comment on this proposal and I appreciate your consideration of my comments.

Sincerely,
Linda F. Cox
Vice President and Compliance Officer
The First National Bank of Mount Dora,
Mount Dora, FL