ATTN: Sheila Bair, ChairpersonFDIC

JULY

LVVY

ucu7-/a3

RE: Equity Firms buying banksDear Chairperson Bair,During this public comment period, we support the

FDIC;

very needed andappropriate controls on Equity Firms buying "failed banks". We believethat oversight, supervision or guidance, transparency and stringent rulescan prevent future financial disasters created by Wall Street et al; runningamok. ~n particular:

The

year rule" would prevent speculators and get-rich-quicklyinvestors from purchasing banks at government offered bargain prices andvery soon thereafter, re-selling them for significant profit. Without your

year rule, the turnaround time will be mind whirling and the cost to thefederal government, gargantuan.

The requirement of being well leveraged, i.e., the

times capitd rule"would ensure that new equity owners were committed to the bnnkk survival andwere willing to support it through difficult times. Otherwise, they couldscheme and scam, those banks would fail anew and once again, the FDIC wouldneed to take over. The rescues and bailouts would never end.

The wish of equity firm owners to remain ambigous and unknown, means thatif there were future financial failings,

tl.2

go;ernment would not know whoto hold accountable. The "blame"/responsibility could be passed from theirghost-like CEOs to Boards of Directors or stockholders or even to middle orlower echelon employees. We have seen this film before and it did not bodewell for our nation; financial health.

It is imperative that equity firm owners and key persons involved in thepurchase, take-over, and day to day running of those banks are known andthat their specific roles, duties and jurisdiction are transparent andclearly delineated in full detail.

The requirement that firms owning more than one bank would need to crossguarantee" leverage to be used when one of their anemic banks requires fundtransfusions from one of their healthier banks. Without that rule, the FDICwould again need to rescue and takeover the sick bank while the equity firmcould avoid responsibility and the government would pay the bill. Alsowithout such cross guarantees, there would be a rush for monopolistic orgreedy equity firmsto buy as auny of the ,aiK+g banks as possible atbargain rates and walk away with impunity, should they fail.

The rule on limiting credit extension to the firms other affiliatedcompanies, will prevent equity firms from siphoning off bank capital and