FDIC Federal Register Citations

Mid Penn Bank
 

From: Alan Dakey

Sent: Friday, June 06, 2008 2:50 PM

To: Comments

Subject: Treatment of secured liabilities, covered bonds- comments

FDIC

I'm writing to provide comments on the Interim Final Policy Statement on Covered Bonds.

The following are my comments:

-- I'm concerned that this policy statement may cover Federal Home Loan Bank advances

which are a major source of funding and liquidity for our institution. Capping these loans would

hamper our ability to serve our customer base. WE consider FHLB loan advances to be a

significant source of liquidity and also a source of matched funding for a portion of our loan portfolio.

-- We have substantial difficulty in attracting longer term deposits and our borrowers want

longer term rates. FHLB advances are a key source of fixed rate funding that can match

our loan pricing terms.

-- We would expect to have higher deposit costs if we were to have to raise more funding

from deposits, a challenging area for us to grow at the same pace we are able to grow loans.

We ask that the FDIC does not penalize our institution by reducing our ability to use

FHLB advances as a reliable and affordable source of funding.

Sincerely,

Alan W. Dakey

President & CEO

Mid Penn Bank

349 Union St.

Millersburg Pa . 17061