Sent: Wednesday, November 12, 2008 9:18 AM
Subject: Comment -- RIN # 3064AD37
Like most lawyers in Maine, I have an IOLTA (Interest on Lawyers' Trust
Accounts), which is my trust account to hold my clients' funds while they
are awaiting disbursement. It is an non-interest bearing account, at least
for me and my clients, but there is interest earned and paid on this
account, and it goes primarily to the Maine Bar Foundation to help fund
areas of significant need in the legal world of the state of Maine. This
arrangement provides great value to those in need of legal services in
I often have well over $250,000 sitting in the account, as funds are
deposited and paid out, so I was very distressed to hear that, under new
rules, the FDIC would not cover more than $250,000. Yet, I understand that
so-called "transaction accounts" (for payroll, etc.) are fully covered.
IOLTA accounts should be fully covered as well. Please change the rule so
such accounts are fully covered.
A recent experience gives one small example. I am holding $560,000 in my
trust account for one client, and because of the financial crisis, she was
concerned that the bank might fail, so we moved $500,000 out of the account
and into another type of account that was protected and would earn her a bit
of interest. If I had to do this type of transaction for every client when
my account's funds were over $250,000, it would be an administrative
Thank you for your consideration.