August 21, 2003
Mr. Robert E. Feldman,
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Mr. Feldman:
I am writing to comment on the proposed rules to amend the deposit
insurance regulations for living trust accounts. I am Vice President and
Compliance Officer of The First National Bank of Mount Dora, a small
independent national bank, with assets of $124 million, located in
central Florida.
Adoption of Alternative Two, which would provide up to $100,000
separate coverage for each owner of the trust, would simplify the
deposit insurance rules for living trusts and make the rules easier to
understand by the customer and bank personnel. It would eliminate
additional recordkeeping requirements for the bank that would be
required by Alternative One. In addition, customers would have the
option to open POD accounts that would be eligible for separate
per-beneficiary POD coverage.
Though Alternative One would, in some instances, provide more
insurance coverage for the living trust account, the rules for this
proposal are more cumbersome and difficult to understand and place a
greater burden of recordkeeping on banks.
I recommend adoption of Alternative Two.
Thank you for the opportunity to comment on this proposal and I
appreciate your consideration of my comments.
Sincerely,
Linda F. Cox
Vice President and Compliance Officer
The First National Bank of Mount Dora,
Mount Dora, FL
