FDIC Federal Register Citations

From: Alicia Hernandez [mailto:ahernandez@dallasbar.org]
Sent: Wednesday, November 12, 2008 9:31 AM
To: Comments
Subject: RIN # 3064-AD37

Ms. Sheila C. Bair
Chair, Federal Deposit Insurance Corporation
550 17th Street, NW
Room 6028
Washington, DC  20429 

Dear Chairman Bair:

I am gravely concerned about the potential unintended consequences to the Interest on Lawyers Trust Accounts (IOLTA) program associated with your announced Temporary Liquidity Guarantee Program (TLGP).

Please make an accommodation as you implement your interim rules to ensure that the critical resources generated by the IOLTA program to provide legal representation to the impoverished are not adversely affected.

IOLTA funds provide a critical source of revenue for legal services programs in Texas.  Without them, program funding will be slashed possibly up to 50%.  This would mean severe cuts in services to the poor who will not otherwise have any hope of getting help for their legal problems.  The door allowing them access to the American justice system will be slammed in their faces.  In addition, legal services programs will be put under such a serious financial strain that job cuts would be likely, sending even more people to the unemployment lines. 

I understand that TLGP is meant to help the banking system.  That is a good thing.  But please make changes to the program that will not have further adverse affects on poor people who are already struggling every day to meet their basic needs.   Please remember them. 

Sincerely,

Alicia E. Hernandez
Attorney & Director
Dallas Volunteer Attorney Program & Community Services
Dallas Bar Association
2101 Ross Avenue
Dallas, TX  75201