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From: Larry Patton [mailto:LPatton@botw-ep.com]
Many banks across the country have reclassified their non interest bearing transaction accounts in order to manage reserve requirements and provide more investable funds into their local communities. This is simply a book entry on the banks part and does not effect the customers view of their deposits and use of their funds. Of course, no interest is paid or accrued on these funds.
We would ask that the final rules governing FDIC coverage on non-interest bearing transaction account balances that are reclassified as described be clearly included in the definition of covered accounts. It is important that banks not be required to increase their reserve requirements and take liquidity out of the system, at a time when it is needed, in order to have the coverage.
Larry L. Patton
|Last Updated 11/03/2008||Regs@fdic.gov|