Federal Deposit
Insurance Corporation

From: Ryan Scaggs
Sent: Wednesday, November 05, 2008 3:25 PM
To: Comments
Subject: RIN 3064-AD35 FDIC Premium Increase for Brokered Deposits 

I feel that putting a premium on the assessment rates for banks that use brokered deposits could be damaging to a large number of banks.  Our bank, for example, has found brokered deposits to be a lower cost, more efficient way to fund the bank because competition in our local markets has pushed retail CDs to unreasonable rates.  We do not use brokered deposits to fund rapid growth, but rather as an alternative to “paying up” for traditional deposits, which makes our bank stronger.  These are a few of the advantages of brokered deposits:

●  Often lower cost

●  Maturities are determined by banks, not by customer preferences

●  Large amounts can be placed very quickly

●  More stable in a liquidity crisis, because money can only be withdrawn early in the event of a customer death

●  Maturities can be laddered out to reduce risk

Thank you. 

Ryan Scaggs
Controller
Macon Bank
One Center Court
Franklin, NC 28734