Federal Deposit
Insurance Corporation

From: Gi-Yu Lin
Sent: Thursday, November 06, 2008 4:37 PM
To: Comments
Subject: Assessments - RIN-3064-AD35 

Regarding increasing FDIC insurance on brokered deposit > 10% of total deposits, please consider adding a threshold  on brokered CD rate, say > 75 basis points over local market rate. In the brokered CD market, sometimes the brokered CD rate is lower than the local CD rate,  in which bank can benefit from it. For your consideration.  

Thanks so much for your help. 

Gi-Yu Lin
EVP and CFO
American Plus Bank, N.A.