via email
From: Marshall, Russell S.
Sent: Wednesday, September 24, 2003 3:04 PM
To: 'regs.comments@federalreserve.gov'; Comments; 'regs.comments@occ.treas.gov';
'regs.comments@ots.treas.gov'
Subject: EGRPRA
I apologize for the lateness of this comment.
Section 18 (c) (1) (C) of the FDI Act requires the FDIC to provide
prior approval, through the application process, for any transfer of
assets to any noninsured bank or institution in consideration of the
assumption of liabilities for any portion of the deposits made in such
insured depository institution. By definition in the Act, a noninsured
bank or institution is one whose deposits are not insured by the FDIC.
Therefore, when an insured financial institution, for example, sells a
branch operation (including assets and deposits) to a credit union,
which is insured by the National Credit Union Administration, it
necessitates an application filing with the FDIC. This application does
not appear to be necessary, as the National Credit Union Administration
is also a quasi-government agency of the U.S. which insures deposit to a
similar extent as the FDIC.
Russell S. Marshall
