August 18, 2003
Federal Deposit Insurance Corporation
500 West Monroe Street, Suite 3300
Chicago, IL 60661-3697
RE: Comments sought about changes to deposit insurance coverage for
LIVING TRUST accounts
To Whom This May Concern:
We at First Federal Savings and Loan strongly recommend that you
select Alternative Plan Two for living trust account insurance.
We feel it would make it easier for the customer to understand and for
the banking institution to maintain.
Alternative Plan One would require us to obtain the complete trust
agreement. Many customers feel most of this is none of our business and
rightly so. It would also be a nightmare for the financial institution
to figure out the specific dollar amounts allocated to specific
individuals as some agreements have complicated conditions that need to
be met as well as assets other than cash to take into consideration.
We like Alternative Plan Two because it would simply require us to
know if there was one or two grantors of the trust, for example, and
therein you would know that the trust was covered up to either $100,000
or $200,000 respectively. Also, the accountholder could have additional
separate coverage in payable on death accounts per each beneficiary
which would be easy to ascertain from the institutions signature card.
We agree that any one institution may not be able to meet the total
insurance coverage for all accountholders. Maybe you should also think
about increasing the insurance coverage per each category as well.
Sincerely,
FIRST FEDERAL SAVINGS AND LOAN ASSOCIATION
Linda Werner
Savings Officer
First Federal Savings and Loan Association
Edwardsville, IL 62025
