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Temporary Liquidity Guarantee Program - Comment on Interim Rule
Dear Sir or Madam:
As a growing community bank, we presently have established federal funds purchased accommodation lines with correspondent banks totaling in excess of $10 million. Such lines were established to assist our bank on a short-term basis during times when we were either in the process of awaiting delivery of longer-term funding or when we experienced an unanticipated short-term request for funds to cover a borrower’s needs. We use our federal funds purchased lines quite sparingly, but they do serve as an invaluable source of secondary liquidity.
On September 30, 2008, we had zero (0) federal funds purchased outstanding.
During this current period of economic uncertainty, will it still be possible for us borrow these funds under the umbrella of the new FDIC debt guarantee program, since many banks, including our correspondent banks have become risk averse to the point where we believe that such requests for funding will be honored only if such borrowings are guaranteed? We have no difficulty with paying an additional fee for such funding capability including the (quite high) 75 basis points you have stated.
Your consideration of this matter for us and other banks will be greatly appreciated.
Francis J. Harrington
|Last Updated 11/04/2008||Regs@fdic.gov|