FDIC Federal Register Citations

From: James York [mailto:jyork@BANKOFNLV.COM]
Sent: Wednesday, November 05, 2008 6:56 PM
To: Comments
Subject: Assessments - RIN-3064-AD35

I have the following concerns with this proposed assessment revision:

• Our bank is only in its 4^th year of operations and have naturally had more than a 20% growth in assets over the last four years.
• We have no brokered cds today but consider them a viable source of liquidity if the need arises.
• Brokered CDs are less likely to run off before their maturity date due to the restrictions for early withdrawal.

It would make more sense to stick to the CAMELS Ratings for measuring the risk of an institution and assessing the deposit premiums. 

James R. York
President/CEO
Bank of North Las Vegas