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Mr. Robert Feldman,
On behalf of Carrollton Bank, I am writing to comment on the FDIC's proposed rule regarding changes to the FDIC insurance assessments to impose higher risk-premiums for federally insured deposits that use FHLB advances (or other secured deposits) in excess of 15% of domestic deposits. I believe that this proposal would increase the cost of funding unnecessarily for our financial institution and discourage the prudent use of advances from the FHLB as a reliable source of funding to supplement core deposits. For this reason, I strongly urge the FDIC to revise or delay implementing this proposal. Thank you for consideration of our institution's views.
William G. O'Neil
|Last Updated 11/05/2008||Regs@fdic.gov|