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FDIC Federal Register Citations

Mr. Robert F. Feldman 
Executive Secretary 
Federal Deposit Insurance Corporation 
550 17th Street, N.W.
Washington, DC 20429


Re: Proposal to Insert 12 C.F.R. 360.7 Dealing with Payment of Post-Insolvency Interest in Failed Bank Receiverships 66 Federal Reqister 65144, December 18, 2001

Dear Mr. Feldman:

The Co-operative Central Bank (the "Central Bank") appreciates the opportunity to comment on the Federal Deposit Insurance Corporation's proposed regulation (12 C.F.R. 360.7) to establish a single uniform interest rate, calculation method, and payment priority for post-insolvency interest in failed bank receiverships (the "Proposed Regulation"). The Central Bank is a special act deposit insurer for Massachusetts co-operative banks established pursuant to Chapter 45 of the Massachusetts Acts of 1932 and Chapter 73 of the Massachusetts Acts of 1934. The Central Bank currently insures any deposits in the 75 co-operative banks in Massachusetts which exceed applicable FDIC deposit insurance limits.

The Central Bank supports immediate adoption of the Proposed Regulation as drafted. The Central Bank believes that the Proposed Regulation provides a fair and balanced approach to resolving the difficult issue of payment of post-insolvency interest in receiverships with surplus funds. It is entirely consistent with the public policy set forth in section 11(d)(11)(A) of the Federal Deposit Insurance Act, the national depositor preference statute, and is in the public interest. By providing a uniform interest rate and depositor priority for distributions of post-insolvency interest, the Proposed Regulation appropriately allocates post-insolvency interest more equitably than at present.

In sum, the Proposed Regulation is in the best interest of all FDIC insured depository institutions and their customers. It will also support and provide stability to the deposit insurance system. The Central Bank unconditionally supports the Proposed Regulation and suggests that it be promulgated in final form promptly.

Very truly yours,

William F. Casey, Jr.

Last Updated 02/01/2002

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