shut down this morning, the banking agencies had arranged to stay open for business as usual. The reason: Bank regulators get their money from banks, not taxpayers. They don't need congressional appropriations to keep operating. Still, the agencies weren't expected to escape completely unscathed from the budget standoff between Congress and President Clinton. The Federal Deposit Insurance Corp., Office of Thrift Supervision, and Office of the Comptroller of the Currency all normally keep their money with the Treasury Department. If the government were still closed next Wednesday and the agencies couldn't write payroll checks on their Treasury accounts, they'd need to come up with another way to pay their employees. Not to worry, said Carolyn Buck, chief counsel of the thrift agency. "In order to make sure money will be available for our purposes, we've placed it in the Federal Home Loan Bank of Des Moines," she said. The Comptroller's office has moved its money to Riggs National Bank in Washington, said spokeswoman Naomi Salus. The FDIC can write its paychecks on an account at Mellon Bank, said William A. Longbrake, the agency's chief financial officer. This switchover would bring a few complications. At the Comptroller's office, Ms. Salus said, employees who normally have their pay deposited directly would have to come in to pick up their checks. At the FDIC, Mr. Longbrake said a crisis team was still working out how the agency would make alimony payments and garnishments normally pulled automatically from employees' pay. The OTS, meanwhile, expected to be able to make direct deposits as usual, said spokesman William Fulwider. The Federal Reserve System doesn't have to worry about any of this. The Federal Reserve Board writes all its checks on an account at the Federal Reserve Bank of Richmond, said board spokesman Joseph R. Coyne. The 12 Federal Reserve banks, meanwhile, are banks - so they can print their own checks. If the budget standoff continued, however, and the Treasury Department defaulted on interest payments, the picture could change. The Comptroller's office and the thrift regulator get their money from application fees and twice-yearly assessments paid by the banks and thrifts they regulate. But the Federal Reserve System gets all its income from interest on the Treasury securities it buys with the money banks must leave on reserve. And the FDIC, though it collects quarterly insurance premiums from banks and thrifts, is becoming more reliant on its Treasury security holdings for income. Both agencies have enough cash that they wouldn't be hurt by one late interest payment. But, said the Fed's Mr. Coyne, "If the Treasury defaulted on everything it had, obviously we would run out of money." And what kind of contingency planning is being done for this eventuality? "There won't be a default," Mr. Coyne said.

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