FDIC Federal Register Citations

From: Jim Caldwell

Sent: Monday, November 10, 2008 11:01 AM

To: Comments

Subject: Assessments - RIN-3064-AD35 

Greetings:  My comments relate to the proposed “Initial Base Assessment Rate” “Pricing Multiplier”:  I don’t think the credit proposed for the “Tier 1 Leverage Ratio (%) is high enough when compared to the size of deductions for “Charge –Offs” and “Nonperforming Loans/Gross Assets (%).  My recommendation is for bank’s that have excess Tier 1 capital, say over 10%, be given a higher credit, for the amount of Tier 1 Capital  over the 10%  that would match the Pricing Multiplier rate on “Net Charge-Offs”.  Without that added consideration banks with extra capital (which is largely the smaller community banks) are not being adequately recognized for the significant added strength that excess capital brings to financial strength and stability.  I appreciate your consideration of this suggestion.  Regards, Jim Caldwell

Jim Caldwell
First Citizens State Bank
Whitewater, WI 53190-0177