From: Ken Mathis
Sent: Monday, March 08, 2004 11:15 AM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
RE: Flood Areas, 12 CFR Part 339
I would like to see this regulation changed to consider
the value of the land first and the value of any attachments
second. If the value of the land, considering the normal
20% equity position, is sufficient to cover the loan
balance, then the value of any attachments is not important.
It is wrong to require a borrower to purchase flood
insurance for a structure that is not even considered
for support of loan repayment.
Thank you,
Kenrick Mathis, Pres.
Texico State Bank
