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