This new system will be more complex and more burdensome, especially for the smaller institutions.  Both the regulators and the bankers have developed a common vocabulary and understanding of terminology.  With all the new increased regulatory burdens and increased paperwork, why would the agencies want to change this vocabulary?

The bottom line is that we seriously question whether there is a big enough problem with the current loan rating system to warrant a completely new rating system.

Thank you for your consideration.

Sincerely,  

Freddie J. Bagley

President and CEO
Community Bancshares of Mississippi