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FDIC Federal Register Citations

Garden Plain State Bank

From: Deneen Fayette [mailto:dfayette@gpsbank.com]
Sent: Friday, October 07, 2005 2:56 PM
To: Comments
Subject: Consolidated Reports or Condition and Income, 3064-0052

My name is Deneen Fayette and I am Senior Vice President at Garden Plain State Bank. Garden Plain State Bank is a $45 million bank located in Wichita Kansas. Because of my previous experience as a FDIC bank examiner, I have been given responsibility at the bank for regulatory reporting. I have been preparing the bank’s Call Report for the past seven and one half years. I would like to comment on the “Proposed Revisions to the Reports of Condition and Income (Call Report)”.

Overall, I agree that the requested revisions will aid regulators in monitoring bank activity and should diminish the amount of information that regulators request for external monitoring. My concerns with the proposal involve the timing of the changes and the length of time between the final approval and the March 31, 2006 implementation date.

The areas that would affect our bank primarily include splitting categories (loan categories, FHLB advances, etc) and are fairly benign on the surface; however, they will require extensive changes to our data processing systems and internal processes. Both will require a fair amount of time. Because the proposed changes are not items that have not been requested in the past, the bank’s systems do not track items requested in the proposal.

Making these changes by the March 31, 2006 Call Report is unreasonable. Although the proposal states that institutions “may report reasonable estimates for any new or revised item in their reports for March 31, 2006, if the information to be reported is not readily available”, the amount of time it will take to manually produce these reports and even estimates will be overwhelming.

For example, the process to split the commercial loans into owner occupied and non-owner occupied properties will take the following steps. 1) Generate a list of all commercial real estate loans. 2) Go though each and every commercial real estate loan file to determine if the property is owner occupied or non-owner occupied and make a list of such. 3) If our computer processor has had adequate time to make the programming changes that allow us to input this data, we would then need to input the occupancy status of each loan and generate a report. If the computer programming has not been changed by the March 31, 2006 deadline, we will then need to manually segregate each loan and add the balances manually at quarter end.

This cumbersome process would also be required for the splitting of construction, land development, and other land loans. And even though the proposal allows for reasonable estimates, the steps described above would also be necessary to provide estimates.

As I hope you can see from my example, these changes will require time to implement. I am asking that you delay the implementation of these changes until at least June 30, 2006 or later, depending on the date the final changes are approved.


Last Updated 10/11/2005 Regs@fdic.gov

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