FDIC Federal Register Citations

From: Larry Patton [mailto:LPatton@botw-ep.com]
Sent: Friday, October 31, 2008 12:06 PM
To: Comments
Subject: RIN#3064-AD37

Many banks across the country have reclassified their non interest bearing transaction accounts in order to manage reserve requirements and provide more investable funds into their local communities. This is simply a book entry on the bank’s part and does not effect the customers view of their deposits and use of their funds. Of course, no interest is paid or accrued on these funds.

We would ask that the final rules governing FDIC coverage on non-interest bearing transaction account balances that are reclassified as described be clearly included in the definition of covered accounts. It is important that banks not be required to increase their reserve requirements and take liquidity out of the system, at a time when it is needed, in order to have the coverage.

Larry L. Patton
President and CEO
Bank of the West
500 N. Mesa St.
El Paso, Texas 79901
915-747-1002
915-747-1025 fax