FDIC Federal Register Citations

Bay State Savings Bank

Comment regarding whether secured liabilities should be factored into assessments:

I am concerned and perplexed that the definition of secured liabilities might include FHLB advances.

FHLB advances provide a means to manage liquidity risk and meet the credit needs of our communities.

A higher assessment charge based on usage of FHLB advances runs counter to a sound, profitable financial institution capable of meeting the housing and development needs of its communities especially during volatile periods in the housing and liquidity markets.

Robert Duquette
Senior Vice President/CFO
Bay State Savings Bank
508-890-9075 (office) 508-751-6459 (fax)
rduquette@baystatesavings.com