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This proposed assessment for brokered deposits seems to be proposed to penalize banks that have any significant dependency on brokered deposits as a funding source as well as any banks experiencing strong growth. Although I do understand that lack of core deposit funding in smaller banks is a cause for some concern to regulatory bodies, this method of collecting additional fees to fund the BIF will have a very significant effect on DeNovo banking institutions such as Carson River Community Bank as our growth rate and our need for brokered deposit funding while we hustle core deposits is an unfair and counterintuitive. The purpose of new regulations which SHOULD be in place to protect and enhance our industrys ability to compete. If you will remember our industry has lost a significant market share for deposits to other non-bank entities over the many years while there is still great demand for community banks in towns and cities across this nation. I strongly urge that our regulators find a more balanced approach to funding the BIF. We dont mind paying our fair share but lets be fair.
Daniel P. Dykes
|Last Updated 11/10/2008||Regs@fdic.gov|