From: Bill Kivit
Sent: Saturday, January 21, 2006 11:22 AM
To: Comments
Subject: Community Banks
By increasing the level of capital required and regulations for community
banks involved in commercial real estate lending, the FDIC will restrict
competition and penalize the very core business that community banks thrive
on. A more practical approach would be to review the quality of the loan
portfolio and amount of loan loss reserve carried. A generic approach
requiring greater capital requirements penalizes community banks that
underwrite sound loans and does not address the issue of poor underwriting.
Poor underwriting will always result in loan losses, despite the level of
capital or regulation. As a result, the problem should be addressed
specifically. A shot gun approach will not limit commercial real estate loan
losses.
Bill Kivit
Vice President
NorthSide Community Bank
