FDIC Federal Register Citations

From: Julie Thurlow
Sent: Tuesday, November 04, 2008 11:08 AM
To: Comments
Subject: Massachusetts State Banks under this extended depositinsurance program

As you may or not be aware, all state chartered banks in Massachusetts with the exception of Eastern Bank that exited their fund had deposit insurance on all their deposits, not just FDIC coverage.

To require Massachusetts state banks to pay premiums on insurance they already have is not appropriate.  The Share Insurance Fund and the Deposit Insurance Fund Coverage reserve ratios are in excess of those of maintained by the FDIC and have already been paid by member banks.   When the FDIC drops coverage at the end of 2009 coverage will revert to these same funds.

Further to erroneously post the Bank's that opt out because they have state insurance on a website identifying them as "not insured" or requiring the notice to depositors of no insurance rather than alternate insurance is also depicting them in a negative light and forcing them to make a costly decision only to save face in light of a media storm.

A separate rule should be developed for the unique 150+ banks that already have deposit insurance and were overlooked when this reactionary development occurred.

Thank you for your consideration.

Julieann Thurlow
President & CEO
Reading Co-operative Bank