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FDIC Executive Secretary Feldman:
I am a Louisiana banker who is writing to comment on the above mentioned proposal. On October 16, 2008, the Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the "Notice") proposing significant changes to its deposit insurance assessment regulation.
I am concerned that the proposal does not differentiate CDARS Reciprocal deposits from traditional brokered deposits, and believe that the factual differences support the FDIC's exclusion of CDARS deposits from the definition of brokered deposit for purposes of the adjusted deposit ratio and the brokered deposit adjustment.
Cost of CDARS
Deposits vs. Traditional Brokered Deposits
CDARS deposits do not exhibit the characteristics that justify the FDIC's increased assessment rule for brokered funds.
for CDARS Deposits
For the above reasons, I believe the FDIC should exclude CDARS deposits from the definition of brokered deposit for purposes of the adjusted deposit ratio and the brokered deposit adjustment. Further, I call on the FDIC to amend the definition of brokered deposits, as it is currently used in the Federal Deposit Insurance Act so that CDARS deposits are accurately categorized as the stable source of funding that they are.
I appreciate the opportunity to comment on the FDIC's proposed regulation.
|Last Updated 10/22/2008