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,
