Commerce Bancshares, Inc.
Compliance Department, TB12-1
922 Walnut P.O. Box 13686
Kansas City, MO 64199-3686
June 24, 2004
FR Document Number: 04-8613
Robert E. Feldman, Executive Secretary
(Attention: Comments/Legal ESS)
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429 via e-mail to: comments@fdic.gov
Dear Sir:
Commerce Bancshares, Inc. is a registered bank holding company with total assets of $15.7 billion at December 31, 2003, and four bank subsidiaries. Three of these banks are full-service banks, with approximately 200 branch locations in Missouri, Illinois, and Kansas. The other bank is a limited-purpose bank, with one office in Omaha, Nebraska. All of the banks are national banks.
The FDIC has asked for comment regarding the application of FDIC insurance to payroll cards. As outlined, if the proposed definition of deposit is implemented, payroll cards may be defined as deposits, thereby qualifying for FDIC insurance. Additional guidance would be consulted to determine whether or not the payroll card is entitled to pass-through insurance. We agree this would be the appropriate treatment for payroll cards. These products are aimed at and for the benefit of consumers who may not have access to a full range of banking services for a variety of reasons. The cards can serve as a vehicle to full integrate these consumers into the economy, as they become accustomed to managing the payroll card account, and using the card as a means to pay for goods and services. These persons deserve the same level of protection the FDIC affords to people who have checking accounts. While the money may be accessed via the payroll card instead of a check, it is on deposit, in the bank, just like the money belonging to the checking account customer. Both should receive the benefit of Federal Deposit Insurance. Thank you for providing the opportunity to comment. Sincerely,
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