Steve Zeman Sent: Monday, November 10, 2008 6:22 PM To: Comments Subject: RIN#3064-AD37 - Temporary Liquidity Program
November 10, 2008
TO: Robert E.
Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429
Dear Mr. Feldman,
While I can certainly
appreciate the efforts being made to strengthen confidence in the banking
system, the rules that we are beginning to see are all coming to us too
fast, with limited information, and with too short of a time span to make
good decisions. I feel that I must not “opt-out” (in other words we will
opt-in) to the TLGP program because we will simply “have to” in order to do
business as usual. Well operated and capitalized community banks like ours
have always found an available market for overnight funds, whether we were
in need of funds or had funds to invest. Now we are being “forced” to
“opt-in” to be sure that the same old banks we always did business with will
continue to want to do business with us. And, we have to pay a very high
price for this.
The 75bp is simply too
high. It will only hurt bank profitability at a critical time. Also,
what will happen after June 30, 2009?
On September 30, 2008
our bank had no borrowings, yet we did at various times in October and just
last week for a few days. Why do we have to use September 30th
as a base value and what process is in place to set an amount for my bank
for future borrowing?
In light of the fact
that almost all community banks have adequate capital and are not the cause
of the current economic crisis I find it very unfair that we have to pay the
75bp’s to do business as usual. Can this be reduced for us? Maybe you
should send troubled institutions to the fed discount window and leave the
rest of us to do business as is.
Steven L. Zeman
Union State Bank of West Salem
120 S. Mill Street, P O Box 870
West Salem, WI 54669