Federal Deposit
Insurance Corporation

March 9, 2006

MEMORANDUM TO: Public Comment File

FROM: James A. Marino
Project Manager
Division of Resolutions and Receiverships, FDIC

SUBJECT: Meeting with JPMorgan Chase Bank

On December 13, 2005 the FDIC published in the Federal Register the Large-Bank Deposit Insurance Determination Modernization Proposal advance notice of proposed rulemaking (ANPR). This ANPR lists three options for comment and solicits other ideas that would allow the FDIC to facilitate an insurance determination in the event of a large-bank failure.

FDIC staff met with JPMorgan Chase Bank representatives in Columbus, Ohio on March 7, 2006 to discuss the ANPR options. JPMorgan Chase participants included staff from government relations, legal and deposit system operations. FDIC participants included Division of Resolutions and Receiverships staff who have worked on various aspects of the ANPR, the dedicated examiner and an IT examiner. Two representatives from the Office of the Comptroller of the Currency also attended.

FDIC staff began the meeting with a brief overview of the bank resolution process. The remainder of the meeting was directed at helping FDIC staff better understand the nature of JPMorgan Chase Bank’s deposit operations and issues relating to the potential implementation of the ANPR options. Bank staff indicated a comment letter may be submitted individually or in conjunction with another respondent.