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Franklin Savings Bank
Robert E. Feldman
I am writing regarding the FDIC solicitation of comments on the treatment of secured liabilities for assessment purposes, and in respect to the consideration of a cap in respect to them.
I am seriously concerned that this would include FHLB advances. Both assessing these advances and limiting their use seems contrary to public policy and the the purpose and interests of the FDIC.
Placing an insurance assessment on uninsured liabilites, particularly upon such an important and utilized source of liquidity to community banks, seems clearly beyond the purpose and interests of the FDIC.
Capping the use of FHLB advances would have dramatically adverse consequences upon the liquidity alternative provided to communities and community banks by the FHLB system. In doing so, this would harm consumers and communities and substantially limit the financing options available to them.
Jeffery B. Savage
|Last Updated 06/23/2008||Regs@fdic.gov|