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FDIC Federal Register Citations
Mohave State Bank

From: Ralph Tapscott  
Sent: Friday, April 22, 2005 12:01 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov; 
regs.comments@ots.treas.gov
Cc: houseworth@azbanking.com; kmore@fdic.gov
Subject: EGRPRA

I compliment your desire to receive input from the industry being impacted.
First off, I believe a compliment is due to the various regulatory bodies
for assisting in the maintenance of the strongest banking industry in the
world.  I also realize that many of the agencies are hard-pressed to
maintain adequate staffing levels to support the continued layering of new
legislative mandates.

Perhaps my motivation for responding is a little self-serving, but I am
compelled to address one small issue.  The frequency of safety and soundness
exams for banks that are considered "well rated".  We are a state chartered
bank with joint supervision by the Arizona State Banking Department and the
FDIC.  We have established a good working relationship with both regulatory
agencies.  Our bank has and has had favorable regulatory reviews over the
past decade.  We are a fairly "vanilla" type bank, and we do not engage in
any significant high-risk activities.  The biggest concern we have at this
time, like many banks in the West, is a concentration in commercial real
estate.  We mitigate this risk with officer training, the maintenance of a
high allowance for loan and lease loss, and maintaining adequate capital -
to name a few.

I would like to see exam cycle stretched to 18 - 24 months for banks that
have historically exhibited sound banking practices.  The various regulatory
bodies do review interim data, they conduct informal management reviews, and
they could always expedite a review cycle if they deemed more than average
risk exists.  Allowing an 18 - 24 month cycle, as opposed to a 12-month exam
cycle, would allow well run banks to continue their focus of being well run
banks.

Thanks for giving me the opportunity to provide my feedback.

Ralph E. Tapscott
President & CEO
Mohave State Bank



Last Updated 04/25/2005 Regs@fdic.gov

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