Federal Deposit
Insurance Corporation

From: Randy Sara
Sent: Tuesday, October 07, 2008 12:10 PM
To: Hunt, Nancy W.
Subject: FIL 100-2008

Good morning, is there a proper way to submit comments on this proposal???

My comments would be that the proposal does not go far enough, in that associated deferred tax liabilities associated with goodwill are only created in "taxable" acquisitions of going concerns, which are limited due to applicability of recapture taxes at the acquired institutions. In non taxable acquisitions, a corresponding deferred tax liability is not created and goodwill STILL WOULD BE SUBTRACTED AT 100%. 

For those acquiring institutions that have not been able to enter into taxable acquisitions, a initial period of not subtracting ANY goodwill would make more sense. This allowance period could be phased out over say five years by 20% per year, thus allowing the acquirer to digest the acquisition and plan accordingly for future capital needs in an orderly fashion.

Further, to keep an even playing field, this treatment should be applied retroactively to acquisitions that have been already occurred over the last four years.