Harrington Sent: Monday, November 03, 2008 2:32 PM To: Comments Subject: Temporary Liquidity Guarantee Program - Comment on Interim
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
Chief Financial Officer
Haven Trust Bank Florida
Ponte Vedra Beach, FL