INDEPENDENT BANKERS ASSOCIATION OF TEXAS July 8, 2004 Via email: comments@fdic.gov Mr. Robert E. Feldman RE: 12 CFR Part 303: Definition of Deposit; Stored Value Cards Dear Mr. Feldman: The Independent Bankers Association of Texas (“IBAT”) wishes to register its support for the proposed amendment in Section 303.16 for the definition “deposit.” This amendment acknowledges the fact that more and more consumers and businesses are using alternatives to traditional checking accounts for a variety of purposes including payroll cards, debit cards that function in lieu of checks, and other electronic delivery modalities. The revised definition will facilitate continued innovation in the use of specialized debit cards or “stored value” cards, and, further facilitate bringing bank services to the currently unbanked. At the same time, the change in the definition rationally recognizes the true beneficial ownership of funds in stored value cards that essentially function like checking accounts with electronic capabilities rather than paper instruments. IBAT believes that general counsel’s opinion #8 was appropriate at the time that it was issued; however, the market place has developed more innovative products that no longer fit within the limitations of GC8. Accordingly, this amendment to the definition is particularly critical in order to facilitate on-going innovation. IBAT is a trade association representing approximately 600 independent community banks domiciled in Texas and Oklahoma. Some of its members are either currently offering such innovative stored valued products or are in the process of evaluating their functionality and attractiveness to the public. Thus, these amendments are of particular interest to our membership. Thank you for this opportunity to comment. Sincerely, Karen M. Neeley |
| Last Updated 07/09/2004 | regs@fdic.gov |