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FDIC Federal Register Citations From: Frank Delay [mailto:fdelay@grandmountainbank.com] After briefly reviewing the proposed rule in regard to deposit
assessments, I have some suggestions which I wish to pass on when
considering this new proposal. My suggestions relate to the proposed
increase in premiums for brokered deposits. We use CDARs as an option for
local depositors and these deposits are currently considered brokered
deposits. Due to the uncertainty in the markets this past quarter, our CDARs
deposits increased from $700,000 to over $6 million. These are deposits
which were held in other banks which did not offer CDARs. We consider these
as core deposits because they are from local depositors and are not
solicited by brokers outside of the area. I would believe there are other
banks with similar programs such as this that only obtain these deposits
from local depositors. Consequently I believe these types of program should
not be considered brokered deposits and should not have a higher deposit
premium than other core deposits. Thank you for your consideration of this request. Frank DeLay
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Last Updated 10/21/2008 | Regs@fdic.gov |