Federal Register Citations
Sent: Thursday, November 06, 2008 3:30 PM
Subject: Assessments - RIN-3064-AD35
would like to comment briefly on the proposal to increase deposit insurance
rates on Brokered CDs. I am not in favor of such a change, which is in
effect a penalty for those choosing to use this funding source. Some of my
Brokered funds are often quite cost effective, providing expense savings
over retail deposit sources. Sometimes those savings are significant. For
example, during the past year, when many banks have been struggling for
liquidity they were driving up the costs of retail money to almost
ridiculous levels. In my case, being in the same market as Wachovia,
because of their thirst for cash the cost of brokered money was often 50
basis points or more less than retail. That is hard to ignore.
In managing the banks interest rate risk, it is often desirable to target
certain terms and blocks of money to offset other risks in the balance
sheet. This is often difficult to do with retail deposits, since it most
often seems that the banks desire for a product conflicts with the
customers. The simplest example of this is that in rising rates
environments, banks would like fixed rate, longer term deposits while
customers want short term, variable rate options. This is quite easily
solved with brokered blocks of money.
Brokered deposits can be very good sources of liquidity. They require no
marketing lead time, and very little administrative effort.
Over time, I believe that many more of what we have considered our core
customers in the past will be doing more of their bank shopping online. As
bank customers become more transient due to the ease of this online
channel, rate will become even more important than it is now. I think the
distinction between the stickiness of core customers versus brokered
will become more dim, and we should not penalize this valid source of
Thank you for your consideration.
P.O. Box 37389
Charlotte, NC 28237