From: Craig Goodlock [mailto:cgoodlock@farmerstatebank.com]
Sent: Tuesday, October 28, 2008 4:37 PM
To: Comments
Subject: RIN # 3064-AD37
Oct. 28, 2008
Federal Deposit Insurance Corporation
Robert E. Feldman, Executive Secretary
By email to: comments@FDIC.gov <mailto:Comments@FDIC.gov>
Attention: Comments RIN # 3064-AD37
Dear Mr. Feldman:
Thank you for this opportunity to submit my comments regarding the
FDIC’s full insurance of non-interest-bearing transaction accounts and
the corporation’s subsequent request for comment regarding extending
that coverage to NOW accounts held by sole proprietorships, non-profit
religious, philanthropic, charitable organizations and the like, or
governmental units for depositing public funds. I will address
specifically the consideration of the extension of insurance coverage to
interest bearing accounts held by governmental units for depositing
public funds.
An analysis of this bank’s deposit composition shows that the increase
in coverage to $250,000 for individual accounts was adequate to insure
all non-interest bearing transaction accounts, including public funds.
However, for years this bank has provided our local municipalities with
competitive interest bearing accounts into which to deposit public
funds. As of Sept. 30, 2008, three of those municipalities had the
following balances in various interest bearing and non-interest bearing
accounts: $1.5 million, $1.2 million, and $6.1 million, respectively.
Obviously, for an increase in insurance to be effective in assisting the
liquidity position of this bank, the coverage needs to be extended to
interest bearing accounts. I urge your consideration in doing so.
Thank you for soliciting and reviewing my comments. I appreciate your
efforts.
Sincerely,
Craig M. Goodlock
President and Chief Executive Officer
Farmers State Bank
201 N. Main St., PO Box 217
Munith, MI 49259
Ph: 517.596.2349 ext. 101
Fax: 517.596.2684
cgoodlock@farmerstatebank.com
www.farmerstatebank.com