FDIC Federal Register Citations

From: Ken Wells [mailto:Ken.Wells@MASCOMABANK.COM]
Sent: Thursday, November 06, 2008 11:25 AM
To: Comments
Cc: ecollier@aba.com
Subject: RIN3064-AD35 

Thank you for the opportunity to comment on the FHLB advance assessment.

We are in an overbanked market where deposit growth can't match loan demand.  Rather than curtail lending practices when the economy needs it most, we rely on FHLB advances for safe, reliable funding.  The advances are collateralized and pose no risk to the FDIC.  It would be like raising the cost of my house insurance if I buy a new car.  If the car was stolen or wrecked the house insurer wouldn't be out a dime.

Please don't harm well-capitalized community banks by assessing premiums on funding sources that pose zero risk to the fund. 

Kenneth D. Wells
Vice President, Retail Lending
Mascoma Savings Bank