FDIC Federal Register Citations

From: Patricia Clausen
Sent: Tuesday, November 04, 2008 9:47 AM
To: Comments
Subject: TEMP LIQ PROGRAM

   I am extremely concerned about parameters of the Loan Guarantee program and the unintended consequence that it may have on the Overnight Fed Funds Market.     We did not have any unsecured debt on the books as of 9/30/08 and we would not qualify for the guarantee.   This guarantee may cause the correspondent banks to only complete FF Purchase for those banks that have this guarantee.  As it stand today 2 of our 6 correspondent banks have pulled the overnight lines.     The bank has no choice but to Opt out of this piece due the fact that we did not have an unsecured line, however, if the fund is not large enough to absorb the losses under the proposed rule all banks would share in the costs.   

  These are extraordinary times and the efforts by the FDIC are greatly appreciated.   The change in deposit coverage was a huge positive for community banks.

Sincerely,
Patricia Clausen