From: Jim Randall
Sent: Friday, January 20, 2006 10:25 AM
To: Comments
Cc: info@icba.org

Subject: subject 2006-01 CRE lending

The proposal to raise capital limits for commercial banks involved with higher levels of commercial real estate and mandate enhanced risk monitoring will severely restrict community banks to compete in the marketplace. This is one area where smaller banks can provide service and value to its customers on a cost effective basis. Having more regulations imposed is micro-managing core banking business and would add to the restrictions already in place for real estate policy exceptions and limitations. As the number of smaller community banks contracts, the regulators should be assisting independent banks to thrive and survive, not impose additional hoops for them to jump through. This proposal will mess with the main engine of income for commercial banks, leave it alone.

Thank you