FDIC Federal Register Citations

From: Gail Jensen-Bigknife [mailto:gjbigknife@Securitybusinessbank.com]
Sent: Wednesday, October 29, 2008 12:41 PM
To: Comments
Subject: RIN#3064-AD37

I wanted to comment on the cost of the Debt Guarantee program, particularly as it relates to smaller community banks. The fixed fee of 75 bp is very high when compared to current market rates. If the Fed Funds rate gets lowered again today, we community banks will suffer even more from the extreme margin compression we are currently experiencing. When you add to that the high fee for us to opt into this program, it becomes a program that we can’t afford. Please consider lowering the fee to 25bp or index the fee to the Fed Funds Target rate so that it becomes affordable for community banks as well.

Gail Jensen-Bigknife | EVP & Chief Credit Officer

Security Business Bank of San Diego
701 B Street, Suite 100
San Diego, CA 92101
619.237.4806 office 619.237.4200 fax
gjbigknife@Securitybusinessbank.com