Federal Deposit
Insurance Corporation

From: Tawana Carter  
Sent: Tuesday, November 04, 2008 3:14 PM
To: Comments
Subject: CALL TO ACTION Proposed Rulemaking on Risk-Based Assessments 
and the Designated Reserve Ratio for 2009

Tawana Carter
Midway, FL 32343-2673


November 4, 2008

Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street NW Attention: Comments/RIN 3064-AD
Washington, DC 20429


Dear Robert Feldman:

As a Florida banker, I would like to comment  regarding the FDIC's 
proposal to increase deposit insurance premiums. We appreciate the 
opportunity to address the issues raised by this request for comment.  
These are extraordinary economic times, and it is important to make sure 
that sound policy choices are implemented.  

The recent adoption of the $700 billion economic stabilization plan had 
one central theme: freeing up credit and preventing this country from 
suffering an economic shutdown. The goal was to make sure that the needs 
of Main Street were addressed along with those of Wall Street. 

In these times, the FDIC should not disrupt the business practices of 
healthy institutions.  Government officials and commentators agree that 
liquidity risk is the most significant challenge facing the banking 
industry today.  It is vitally important not to harm the institutions that 
provide liquidity, which often are institutions so important to Main 
Street.  

Instead of adopting this proposed rule, we believe the FDIC could better 
achieve its policy goals by taking these steps: The FDIC should utilize 
its extraordinary circumstances authority to extend the time period to 
rebuild the FDIC fund from five to ten years. This will limit unnecessary 
stress on insured depositary institutions.

The FDIC should establish new premium schedule at the end of 2009. This is 
a more prudent timeframe to establish a new premium schedule given the 
current environment and the temporary emergency actions taken by the 
government that will expire in 2009.

Advances from Federal Home Loan Banks are a vital source of liquidity for 
our members.  FHLBank advances provide banks with access to reliable and 
stable low-cost funding.  For many banks, FHLBank advances are the 
lifeblood of their credit. This helps our banks serve the credit needs of 
their communities, support homeownership, and assist local community 
development.  Anything that would penalize the use of advances would 
thwart the efforts by the Treasury, Congress and the Federal Reserve to 
restore liquidity to the credit markets.  

Certain provisions in the regulations would increase deposit insurance 
premiums and levy even higher premiums associated with the use of FHLBank 
advances. These proposed increases would make lending money more expensive 
just at a time when the national goal is to lower the cost of borrowing. 
It would be counterproductive, in this economic atmosphere, to make it 
harder for banks to function by raising their cost of doing business. Many 
institutions would extend less credit in their communities, which  would 
harm those communities and the broader economy as a whole. We encourage 
you to carefully reexamine this proposal and withdraw the proposed higher 
premium on the use of FHLBank advances.

Thank you for the opportunity to comment about the proposed FDIC 
regulation. 


Sincerely,

Tawana Carter