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From: Ellie Fox Sent: Wednesday, November 12, 2008 2:43 PM To: Comments Subject: Assessments - RIN-3064-AD35
November 12, 2008
RE: FDIC ASSESSMENT PROPOSAL
Dear Sir or Madam:
As of 2007, my bank, Colonial Co-operative Bank, with approximately 72 million in assets, pays 6.85 bp assessment.
Ø I have no debt on my balance sheet. I have a 2 million dollar line of credit from the FHLB, but have never borrowed any money.
Ø I do not have adjustable rate mortgages.
Ø I do not sell my loans.
Ø I do not accept brokered deposits.
Ø I do not have subprime loans.
Ø I do not invest in national or international instruments.
Regardless of the above, my 6.85 bp assessment will instantly rise to 9.872, which represents a 44% increase. Using the financial calculator on FDIC.Gov, this new base is estimated to increase to 13.76, which represents 101% increase.
I think this is an unconscionable increase. Even health care costs ONLY accelerate 20% or so in any given year. I am more than willing to pay my fair share, but my fair share should not equal a 101% increase!
I would prefer that you maintain the current multipliers, which just 2 short years ago were the latest and greatest and increase the impact of the new adjustments, i.e., the brokered deposit adjustment, the borrowed fund adjustment, so that those sophisticated folks who utilized these services will pay more of the assessment increase.
I would suggest that you include some kind of deductibles, such that should I choose to self fund, I could reduce my base bp amount by so much per $100,000.
Please contact me if you have any questions.
(Ellie) J. Fox
|Last Updated 11/13/2008||Regs@fdic.gov|