FDIC Federal Register Citations

From: Dennis King
Sent: Wednesday, November 05, 2008 6:41 PM
To: Comments
Subject: RIN 3064-AD35 

"Brokered" is not a 4-letter word!.  Brokered Deposits can be a cost-effective funding source, often times less expensive than other funding sources.    As far as a liquidity source, they are especially important to community banks in our present economic environment.    The benchmarks of 10% brokered and 20% growth are unrealistically low and are in no way reflective of risk to the deposit insurance fund.  For banks that have been established for over 10 years, the 20% growth limitation seems more reasonable.    

Deposits gathered from listing services should be treated the same as those gathered from normal marketing/advertising.  They should not be counted as brokered deposits! 

Dennis M. King
Chief Credit Officer
North County Bank