FDIC Federal Register Citations

From: Frank Delay [mailto:fdelay@grandmountainbank.com]
Sent: Monday, October 20, 2008 9:49 PM
To: Assessments
Subject: Proposed Rule

After briefly reviewing the proposed rule in regard to deposit assessments, I have some suggestions which I wish to pass on when considering this new proposal. My suggestions relate to the proposed increase in premiums for brokered deposits. We use CDARs as an option for local depositors and these deposits are currently considered brokered deposits. Due to the uncertainty in the markets this past quarter, our CDARs deposits increased from $700,000 to over $6 million. These are deposits which were held in other banks which did not offer CDARs. We consider these as core deposits because they are from local depositors and are not solicited by brokers outside of the area. I would believe there are other banks with similar programs such as this that only obtain these deposits from local depositors. Consequently I believe these types of program should not be considered brokered deposits and should not have a higher deposit premium than other core deposits.

Thank you for your consideration of this request.

Frank DeLay
President and CEO
Grand Mountain Bank, FSB
337 E Agate
Granby, CO 80446
Phone - 970-887-1221