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FDIC Federal Register Citations

Southern Missouri Bank & Trust

From: Matt Funke [mailto:mfunke@smbtonline.com]
Sent: Friday, May 26, 2006 1:27 PM
To: Comments
Subject: 3064-ADO7

May 25, 2006

VIA E-MAIL
Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Dear Mr. Feldman,

I am writing to provide comment regarding proposed rules allocating the one-time assessment credits authorized under the Deposit Insurance Reform Act of 2005 on behalf of Southern Missouri Bank & Trust, a community bank headquartered in Poplar Bluff, Missouri.

We understand the need to begin replenishments of the Deposit Insurance Fund, and applaud the actions of Congress to recognize that institutions which have previously paid insurance premiums ought to receive credit for those payments. Additionally, we understand the reasoning behind the FDIC’s decision to interpret the undefined term “successor” to include mergers and consolidations, but to exclude purchasers of deposits (e.g., branch sales). As an institution with both branch sales and purchases since 1996, we stand to sustain little impact from the decision, but it is our opinion, nevertheless, that the proper measurement would follow the deposits, rather than the charter. While this would mean some additional work in tracking deposit sales, we believe that the deposits which generated the premiums paid are a truer measure of to whom credit is due than simple charter transfers.

Southern Missouri Bank appreciates the opportunity to comment on this matter and the consideration we know will be given our thoughts on it.

Sincerely,

Matt Funke
Chief Financial Officer
Southern Missouri Bank & Trust

 


Last Updated 05/30/2006 Regs@fdic.gov

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