FDIC Federal Register Citations

From: Steve Handke
Sent: Friday, October 17, 2008 3:53 PM
To: Comments
Subject: Federal Deposit Insurance Corporation Notice of Proposed Rulemaking,

Robert E. Feldman
Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC  20429

Re:       Federal Deposit Insurance Corporation Notice of Proposed Rulemaking, RIN 3064-AD35

Dear Mr. Feldman:

I am the President of The Union State Bank of Everest, which has $102,180,000 in assets and 3 locations in Kansas. We are a member of the Promontory Interfinancial Network and offer CDARS Reciprocal Deposits to our customers.  CDARS is a valuable tool in retaining large local deposits. Just last week after the House defeated the first Banking bill, we had a large commercial customer consider moving $4,000,000 (5% of our deposits) out of our bank into Treasury securities. Because we had CEDARS, our bank was able to keep this local deposit in our local market.

I tell this anecdotal story because it demonstrates my point that CDARS deposits are local deposits and should be treated as such for FDIC assessment purposed. Please do not aggregate these deposits with Brokered deposits for insurance assessment purposes as they have nothing in common. Thank you.

Steven J. Handke
President, CEO
Union State Bank