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FDIC Federal Register Citations

Sent: Wednesday, November 12, 2008 5:22 PM
To: Comments
Subject: RIN # 3064-AD37

To Whom It May Concern:

I am an attorney in private practice in Texas very interested in legal services to the poor.

Straight to the point … in my judgment, the Temporary Liquidity Guarantee Program will have dire consequences on the poor who seek basic legal representation from entities funded, even in part, by Interest on Lawyers Trust Accounts (IOLTA) monies.

On a monthly basis, I look at my IOLTA bank statements and, notwithstanding the credits to the account, I fuss about the attorney’s fees my clients owe, know they owe and have absolutely no intention of paying unless I sue them. I think about what I could do with those attorney’s fees owed to me. Yes, I make a fuss every month as if someone listens and responds.

However, I never – and that’s a real-world never, not a defense lawyer’s punishment argument “never” - complain that the interest on that account is credited on one day and debited the same day. Gone. I refuse to complain because I know that money goes to a worthy cause – not my overpriced car, home, wardrobe, vacations, etc. That is one debit on my business that never frustrates, always delivers.

I urge consideration of IOLTA accounts as non-interest bearing accounts under the terms of the TLGP. Alternatively, because attorneys must have a plan B for the clients whose situations require it, I ask an exception be made in the TLGP interim rules providing unlimited deposit insurance to IOLTA accounts.

Your attention to this correspondence is appreciated.


Marvina N. Robinson
Marvina N. Robinson, PC, Attorney at Law
601 Strada Circle, Suite 105
Mansfield, Texas 76063


Last Updated 11/13/2008

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