Public Comment One Time Assessment Credit Nationwide Bank, Columbus, OH

Nationwide Banksu On Your Side" Member FD~C VIA EMAIL & OVERNIGHT MAIL August 15.2006 Robert E. Feldman Executive Secretary Federal Deposit Insurance Corporation 550 17" Street, N.W. Washington, D.C. 20429 Subject: RIN 3064-AD08 (One-Time Assessment Credits) RIN 3064-AD02 (Designated Reserve Ratio or "DRR) Dear Executive Secretary Feldrnan: Nationwide Bank is pleased to comment upon the above referenced proposed rules. Nationwide applauds the effort to build a sound and f& deposit insurance system. However, to address the potential for unintended adverse consequences under the proposed rules that could impact institutions like Nationwide Bank, we recommend a phased-in approach of the Dm and the one- time credit. The proposed rules would implement the Federal Deposit Insurance Reform Act of 2005 which, among other things, eliminated the fixed designated reserve ratio of 1.25%, establishing a range of between 1.15% and 1.50% and directing the Board of the Corporation to set and publish annually a DRR for the Deposit Insurance Fund rDIF"). The proposed rules also would implement a one-time assessment credit to eligible insured depository institutions which are institutions that paid an prior to December 3 1, 1996, by establishing a limit on the credit of up to 90% of an institution's assessment. Nationwide Bank supports a sound and fair deposit insurance system. It's a positive for soundness to the system that all institutions be required to ...