FDIC Federal Register Citations

From: Janice Mulligan
Sent: Tuesday, November 11, 2008 7:41 PM
To: Comments
Subject: RIN # 3064--AD37

The purpose of this email is to voice an objection to the exclusion of IOLTA accounts from the TLGP. Lawyer Trust Accounts (IOTLA) are  transactional accounts and generate interest to a third-party non profit program that provides grants for much needed legal aid. 

The failure to include IOLTA accounts in the TLGP puts attorneys such as myself in a terrible predicament. My primary duty is to my clients and as such,  unless IOLTA accounts are protected under the TLGP, I must move my client's trust money to fully insured non-interest bearing accounts.

However, as an officer of the court, I know that this results in a huge blow to legal aid at a time when such funds are sorely needed. In addition, because the trust accounts may be moved to fully insured but non-interest bearing accounts, the banks will reap an unintended windfall by retaining money that should be paid out in interest.

Please reconsider this unjust decision, and allow IOLTA funds to become a part of the TLGP. It is the only right thing to do so that justice may be served.

Sincerely,

Janice F. Mulligan
MULLIGAN & BANHAM
2442 4th Avenue, Suite 100
San Diego, CA 92101