FDIC Federal Register Citations

From: Bill Tandy
Sent: Thursday, November 06, 2008 1:11 PM
To: Comments
Subject: Currently Proposed FDIC Premiums

To Whom It May Concern:

I, in the strongest terms, urge the F.D.I.C. to either repeal entirely or pare back substantially the proposed F.D.I.C. premium increases. 

It strikes me that the overwhelming majority of 8,500 or so banks in the United States are in good to very good financial shape. These banks are in good shape largely because they are well managed and partly because we have had good regulation and effective oversight. Unlike the banking industry, Fannie Mae, Freddie Mac, Merrill Lynch, Goldman Sachs and the like, have had little to no oversight. And contrary to the media this was not caused by deregulation it was in fact a complete lack of oversight. This lack of oversight was, in my opinion, a complete disregard for taxpayer safety, incompetence in the discharge of their duty and a conflict of interest and in many cases on the part of Congress.

While I am not privy to the political ins and outs of what really happened here, it seems to me that the current F.D.I.C. insurance fund problem came about largely due to the addition of Merrill Lynch, Goldman Sachs and the like to the F.D.I.C. insurance fund. Unfortunately, the problem assets they bring completely dwarf any kind of financial assessment they could have made to the insurance fund on their own behalf. And if in fact the insurance fund is short because of their addition, then wouldn’t it seem reasonable that the shortfall in the insurance fund should be made up by those newly added institutions, other healthy investment firms and the Federal Government, regardless of whether the F.D.I.C. volunteered to take responsibility for these institutions or F.D.I.C. was otherwise volunteered to do so.

Either way,  in terms of affect, this situation is not unlike the savings and loan crisis of the 1980’s when the banking community was then wrongfully asked to pay billions of dollars for the financial clean up, chaos and losses in that industry. 

I would respectively suggest it is completely wrong, to once again, to force the banking community to pay for that which we had no hand in making.

If Merrill and Goldman and for that matter WAMU and IndyMac as well were as well run and had had the same regulation and oversight as the banking industry, this letter wouldn’t be necessary.

Respectfully submitted,

William M. Tandy
President and C.E.O.
Pueblo Bank & Trust