FDIC Federal Register Citations

From: Steve Witcher
Sent: Monday, November 03, 2008 3:55 PM
To: Comments
Cc: Daniel Tanner; Mary Sue Voth; Chris Foxen
Subject: RIN number 3064-AD35.

Gentlemen: 

We do not feel that internet CD’s and CD’s that are generated from Internet Rate Posting Boards should be considered the same as Brokered Deposits.  Brokered deposits involve the negotiation of a third person where as the rate posting boards such as Qwick Rate only offer the investor the opportunity to shop rates before purchasing CD’s.  There is no third party involvement and only the investor makes the decision to invest.   These CD’s should not be considered in the proposed adjusted brokered deposit ratio.  Those CD’s that are generated from listing services are not presently considered a brokered CD and should not be in the future.  These listing services provide a great benefit to community banks that are not in communities with an abundance of deposits and there is a very strong demand for loans.  The deposits are needed to help fund the loans that the community needs. 

We urge the FDIC to maintain the non brokered status of Internet and rate listing service deposits and to not incorporate these deposit funding resources into the “adjusted brokered deposit ratio”. 

Thank you very much.

Stephen T. Witcher
Vice President and Cashier
Canon National Bank
Canon City, Colorado
FDIC # 21801