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Bay State Savings Bank
Comment regarding whether secured liabilities should be factored into assessments:
I am concerned and perplexed that the definition of secured liabilities might include FHLB advances.
FHLB advances provide a means to manage liquidity risk and meet the credit needs of our communities.
A higher assessment charge based on usage of FHLB advances runs counter
to a sound, profitable financial institution capable of meeting the housing
and development needs of its communities especially during volatile periods
in the housing and liquidity markets.
|Last Updated 06/23/2008||Regs@fdic.gov|