Wrabetz Sent: Monday, November 10, 2008 10:05 AM To: Comments Subject: FDIC RIN 3064-AD37
TLGP, on the surface, appear to offer the banking industry much needed
relief. However, community banks with no unsecured debt at September 30,
2008 are being forced to a: negotiate with their primary regulator (FDIC)
for some level of coverage through an undefined formula in order to have any
coverage at all; and b: "opt in" (even though this happens through no
action) in order to access the Fed Funds market at market rates. These same
community banks, at least this one, were not responsible for the economic
chaos currently in evidence.
Between these proposals and other proposed changes to insurance assessments,
we now face quarterly assessments in excess of $100,000. While it is part
of our duty as bankers, draining the capital of well-run community banks to
prop up poorly run mega-banks can't be the right answer. Please reconsider
what you ask of us and extend the deadline for the "opt out" decision at
least until all the facts are known.