Federal Deposit
Insurance Corporation

Mr. Robert Feldman,

 

I want to take this opportunity to comment on the proposed changes and reserve allotments to the ALLL. This is a bad idea for community banks. There may be some need to evaluate on par the largest banks for Basel II purposes but extending this to all banks is in my opinion not sound public policy. We are a State chartered group of institutions and have come to believe in the specific allocation method of reserving with general reserve over and above specific allocations. We take comfort in our examiners both at FDIC and State affirming this reserve level. Please, do not change this methodology to something far more arbitrary.

 

Gary L. Nelon

Chairman/CEO

First Texas Bancorp, Inc.