FDIC Federal Register Citations

From: Sarah Evans [mailto:sarah@SSHBClaw.com]
Sent: Wednesday, November 12, 2008 5:10 PM
To: Comments
Cc: jstrandlie@staff.abanet.org; Office
Subject: RIN # 3064-AD37

I am a long-time board member of the San Diego Advocates for Social Justice (dba San Diego Advocates for Affordable Housing), a legal services organization that receives funding from many sources, including from California's Legal Services Trust Fund which in turn is funded by IOLTA funds. I understand that the above-referenced rule revision proposes that these IOLTA accounts may not be included in the Temporary Liquidity Guarantee Program, which would be a mistake.

If attorneys are forced to move their trust accounts to non-interest bearing accounts which are protected under the TLGP, then less will be available for distribution to needy legal services providers, who do good work. For example, we have used IOLTA monies to help fund legal battles regarding proper allocation of redevelopment tax proceeds; just last year, we forced the City of Brea to build an additional 208 affordable units to make up for past shortfalls. As a result of prudent use of IOLTA funds and other sources, AHA has forced other communities in southern Calfornia to build many additional affordable units, which are always valuable.

Furthermore, IOLTA funds help support AHA's Tenants’ Right Project, which provides legal services to tenants, nonprofit community organizers and their constituents, to advocate for affordable housing and tenants’ rights. We hope that you will continue to protect IOLTA funds under the TLGP.

Please let me know if you have any questions about this. Thank you,

Sarah Evans
Schwartz Semerdjian Haile Ballard & Cauley LLP
101 West Broadway, Suite 810
San Diego, CA 92101-8229