FDIC Federal Register Citations

From: Mark Evans [mailto:mevans@viningsparks.com]
Sent: Friday, October 24, 2008 1:58 PM
To: tglp@fdic.gov; Comments
Subject: RIN # 3064-AD37

Regarding the TGLP Interim Rule

This is minor and trivial but I wanted to point it out just in case it matters.

One question about the guidance. Pages 7-8 describing the notice indicate that the institution must disclose that institutions must “disclose those actions to the affected customers and clearly advise them in writing that such actions will void the transaction account guarantee” if “the institution uses sweep arrangements or takes other actions that result in funds in a noninterest-bearing transaction account being transferred to or reclassified as an interest-bearing account or a non-transaction account.” But the details of the guidance allow an exception when the sweep is to a non-interest bearing savings account.

So, an edit may be needed to require notice if the sweep results in the account being not covered by the program.

Thanks for all of your diligent work on these matters.

Mark Evans, CFA
Vining Sparks
mevans@viningsparks.com
800-829-0321 901-766-3260 fax 762-6801
775 Ridge Lake Blvd, Memphis 38120