Federal Deposit
Insurance Corporation

TO: Mr. Robert E. Feldman
      Executive Secretary
      Attn: Comments/Legal ESS
      Federal Deposit Insurance Corporation
      550 17th St., NW
      Washington, DC 20429

FROM: Tom Ayers, SunTrust Bank

SUBJECT: Part 330 – Stored Value Cards

Dear Mr. Feldman:

This comment letter is submitted on behalf of SunTrust Bank, a Georgia banking corporation, in response to a new proposed rule issued by the Federal Deposit Insurance Corporation as a replacement for its April 2004 proposed rule, to clarify when funds at insured depository institutions underlying prepaid cards would constitute “deposits” under the Federal Deposit Insurance Act. The proposed rule could extend deposit insurance coverage broadly to a variety of prepaid products, including payroll cards and gift cards.

SunTrust believes that the proposed rule ignores the core policy implications of deposit insurance coverage and fails to recognize important differences between different types of prepaid cards. This matter is of great importance not just to SunTrust but to the entire banking industry.

So that our opinion is included in your analysis, we have reviewed the comment letters sent by the American Bankers Association and Visa U.S.A. Inc. and give our full endorsement of the positions taken by these organizations.

Thank you for the opportunity to comment on this significant matter. If you have any questions concerning the above, please do not hesitate to contact me, at 404-658-4132.

Tom Ayers

VP, Product Management
SunTrust Bank
303 Peachtree Center Ave. NE
Suite 300
Atlanta, GA 30303