From: Fred Riepen [mailto:email@example.com]
Sent: Wednesday, November 12, 2008 6:05 PM
Subject: RIN # 3064-AD37
Please addressand seek correction as to the issue which has arisen since
passage of the recent "bail out" legislation and proposed
regulations which, we are told, will limit the FDIC guarantee as
relates to balances held in lawyer trust accounts under the IOLTA
program as adopted in Texas. As you may be aware, this program does
not provide any benefits to lawyers, as such, but instead, exists solely
]to provide absolutely essential funding for proverty law programs.
We, as lawyers, and as participants in local programs like our new Fort
Bend Lawyers Care not for profit entity which we chartered to provide
pro-bono legal services to deserving low income individuals, fear that the
limiting of the FDIC guarantee on our IOLTA trust accounts, and thus
forcing the transfer of higher dollar sums to other non interest bearing
accounts, will result in substantial curtailment of interest earnings and
therefore a resulting loss of funds otherwise available to fund
poverty law programs - thus resulting in a substantial harm to beneficiaries
receive pro bono legal services.
Another consequence, while incidental, will be a certain windfall to the
participating banks, who will have the use of these trust funds for
free - a seemingly inappropriate, even if unintended, result.