From: Fred Lutz [mailto:FLutz@Bank-Northwest.com]
Sent: Friday, October 24, 2008 12:44 PM
Subject: RIN 3064-AD37
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