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Letters to Regulators

Certified Statement Invoices

August 6, 2004

Robert E. Feldman
Executive Secretary
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC 20429

Re: Part 327 - Certified Statements

Dear Mr. Feldman:

The Independent Community Bankers of America (ICBA)1 appreciates the opportunity to comment on the Federal Deposit Insurance Corporation's (FDIC) proposal to modernize and simplify its deposit insurance assessment regulations governing the use of certified statements. Under the proposal, insured institutions would obtain their certified statements on the Internet via the FDIC's transaction-based e-business website, FDICconnect. ICBA generally supports the FDIC's proposal.

Overview

Under the Certified Statement Invoice proposal, there would be no need for a bank to certify the accuracy of the information in the certificate or invoice by signing the form and returning it to the FDIC before payment is made, as is currently required. Instead, the bank would access its statement online. If the invoice is correct, the bank would simply pay it by funding its designated account and permitting the FDIC's direct debit and retain the invoice for its files.

If the invoice is not correct, the bank would pay the amount specified and either correct the erroneous information on the Call Report or amend the invoice to show the desired change, sign it and return it to the FDIC within the specified time frame. For incorrect invoices, these actions would automatically constitute appeal of the assessment amount.

ICBA Comments

Community banks generally do not consider the current procedure to be burdensome or unnecessarily cumbersome. Nonetheless, they, and the ICBA, support automating and streamlining the invoice assessment system. However, as some banks may not have ready access to the Internet, ICBA recommends that the FDIC offer alternative means for those banks. ICBA recommends such alternatives as fax or mail at the bank's option. For banks that use the new system, ICBA also strongly recommends that the FDIC send an automated email to banks to notify them when their invoices are available online. Such email notification would ensure that banks do not neglect to check their certified statements online or overlook funding their account in a timely manner for the FDIC's direct debit.

ICBA also supports the new system of filing an appeal by correcting the Call Report or amending the invoice, as it eliminates an added step in the appeals process since the amendment of the Call Report or the returning of the invoice noting the discrepancy would constitute the appeal.

Conclusion

ICBA supports the FDIC's proposal to automate the certified statement invoice assessment process. If the proposal is instituted, ICBA strongly promotes the addition of a notification email sent to banks alerting them that their certified statement invoice is available online.

Thank you for the opportunity to comment. If you would like further information on this subject, please contact Chris Cole, ICBA Regulatory Counsel, at 202-659-8111 or chris.cole@icba.org.

Sincerely,

Karen M. Thomas
Executive Vice President
Director, Regulatory Relations Group

1 ICBA represents the largest constituency of community banks in the nation and is dedicated exclusively to protecting the interests of the community banking industry. We aggregate the power of our members to provide a voice for community banking interests in Washington, resources to enhance community bank education and marketability, and profitability options to help community banks compete in an ever-changing marketplace.






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