From: Joe Wachtel [mailto:joe@monitorbank.com]
Sent: Friday, October 07, 2005 2:25 PM
To: Comments
Subject: Consolidated Reports of Condition and Income, 3064-0052

While there may be benefits in some of the changes, others just create more work and have nothing to do with safety and soundness ... for example, splitting "construction, land development, and other land loans" and splitting "nonfarm nonresidential properties". This seems to follow the ever-growing mentality of the regulators that bankers are just a bunch of bumbling idiots who couldn't open the doors of their banks without advise from the regulators. Also, the revised director attestation indicating that signing directors have reviewed the report is ridiculous. No one just "reviews" a call report. All supporting documents must be reviewed and a thorough understanding of the report is a must. This would realistically require hours of time for the review, with continuing education for what are part-time directors holding down other jobs or running their own business. This would be the same as regulators understanding all the sophisticated documents and reports of the businesses the directors are involved in - impossible at best.