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From: Fred Lutz [mailto:FLutz@Bank-Northwest.com]
Thank you for the opportunity to comment on the Temporary Liquidity Guarantee Program. I feel that mandating institutions who opt-out of the Transaction Account Program to publish this fact would be counterproductive to the intent of stabilizing the economy.
I feel clarification is needed as to the extent of the coverage for noninterest-bearing accounts and the additional 10 basis point fee for amounts in excess of $250,000.00. In the example given; all noninterest-bearing transaction accounts would be covered separately from any other deposits at the institution. I would further suppose that a fee would not be charged to institutions for this added coverage until such time as the noninterest-bearing balance(s) would exceed $250,000.00.
You may find that customers of well run banks are not looking for additional FDIC coverage that they (ultimately) will pay the premium. Business customers are doing business with banks that they trust and know.
In my opinion, the Transaction Account Program is not needed.
Fred A. Lutz CRCM
|Last Updated 10/29/2008||Regs@fdic.gov|