I think when rules are proposed there is little if any thought given to the effects of a small community bank. By small I mean an institution such as ours. We are a $28mm bank with a total of 9 employees. A re-write like the proposal will require changes in our loan policy and internal classification system. Banks our size are rapidly approaching the point where the amount of regulations make them financially unfeasible since we can not hire full time compliance officers.

If the intent of regulators is to regulate us out of existence just do that with one reg rather than killing us slowly by continually changing regulations that then require more work in order to be in compliance.The existing regulations regarding loan classifications have served the industry well for many years. Please concentrate on something that can have an impact--like regulatory relief for small community banks.