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FDIC Federal Register Citations

August 29, 2003

Robert E Feldman, Executive Secretary
Attn: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street
Washington DC 20429

 RE: Deposit Insurance Regulations / Living Trust Accounts

 Dear Mr. Feldman:

I agree that proposed rule - alternative one - would better simplify FDIC insurance rules for living trust accounts. With defeating contingencies removed from consideration of FDIC insurance coverage, alternative one addresses the most confusing part of these coverage rules.

Considering that many of these accounts are established to protect an individual's assets from estate taxes, and that these individuals are possibly a bank's most desirable customer due to the potential of large deposits, it would be beneficial for a bank to be able to explain the "per qualifying beneficiary" coverage. This will provide banks with a tremendous opportunity to retain those deposits - instead of seeing the customer walk to the nearest brokerage company.

The bank should review the original agreement in order to explain FDIC coverage at account opening. However, in determining coverage due to a bank's failure, the burden of proof must be placed upon the depositor, because amendments to the original agreement may have occurred subsequent to account opening.

I do not support alternative two solely due to the possibility of decreased coverage on existing living trust accounts.

William H. Mitchell
Senior Vice President/CFO
Calvin B. Taylor Banking Company
Berlin, MD

Last Updated 09/05/2003

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