FDIC Federal Register Citations

From: Jay Randall
Sent: Monday, November 10, 2008 5:30 PM
To: Comments
Subject: RIN #3064-AD37 

Comments on the (TLGP) Temporary Liquidity Guaranty Program 

I feel that we (Community Bank, Dunlap, IA) are a well run, well capitalized institution.   

The “Opt Out” provision of this program leaves me wondering why the publishing of the bank listing when we “Opt Out” shouldn’t be the other way around.  Those that feel they need this additional coverage should disclose the fact.  By listing well run, well capitalized institutions just because they choose to “Opt Out” might lead the public to think they are not a safe institution, which is not true.

As a user of correspondent banking services, I’ve learned that should I need to borrow funds through them, that the cost may reflect “tiered-pricing” because of the TLGP.  It seems that this isn’t equitable to strong community banks.

While I don’t anticipate the need to participate in the TLGP, it does seem to have a high cost.  I feel like we are being forced to participate to protect our good name.  By running a safe, secure and fundamentally strong financial institution, we are NOT putting the FDIC funds at risk.

I have thought that the TLGP is structured wrong for an insurance company.  If all strong financial institutions “Opt Out” and only the weak participate, isn’t there great risk of adverse selection? 

Jay T Randall, President
Community Bank
601 Iowa Ave., PO Box 145
Dunlap, IA  51529-0145