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We do not feel that internet CDs and CDs that are generated from Internet Rate Posting Boards should be considered the same as Brokered Deposits. Brokered deposits involve the negotiation of a third person where as the rate posting boards such as Qwick Rate only offer the investor the opportunity to shop rates before purchasing CDs. There is no third party involvement and only the investor makes the decision to invest. These CDs should not be considered in the proposed adjusted brokered deposit ratio. Those CDs that are generated from listing services are not presently considered a brokered CD and should not be in the future. These listing services provide a great benefit to community banks that are not in communities with an abundance of deposits and there is a very strong demand for loans. The deposits are needed to help fund the loans that the community needs.
We urge the FDIC to maintain the non brokered status of Internet and rate listing service deposits and to not incorporate these deposit funding resources into the adjusted brokered deposit ratio.
Thank you very much.
Stephen T. Witcher
|Last Updated 11/04/2008||Regs@fdic.gov|