From: Kay Riebold [mailto:KWR@BankofWhitman.com]
Sent: Tuesday, March 14, 2006 6:52 PM
To: regs.comments@federalreserve.gov; regs.comments@occ.treas.gov; Comments;
regs.comments@ots.treas.gov
Cc: James Tribbett; Katie Bragan; icbawest@icba.org; Craig Conklin; Bill
Knox
Subject: Comments Dockets No 06-01;Docket No OP-1248; Docket No 2006-01
This is being sent on behalf of Craig Conklin, Vice Pres./Chief Lending
Officer of Bank of Whitman, S. 201 Main, Colfax, WA 99111 (509) 397-4629
www.dcc@bankofwhitman.com
OCC – Comments to Docket No. 06-01
Board - Comments to Docket No. OP-1248
OTS – Comments to Docket No. 2006-01
RE: Concentrations in Commercial Real Estate Lending, Sound Risk
Management Practices
After our review of the Concentrations in Commercial Real Estate Lending,
Sound Risk Management Practices, Bank of Whitman has the following comments:
• The proposed thresholds of 100% and 300% are too restrictive for
community banks.
• The detailed analysis and management system being recommended is cost
prohibitive to smaller banks. Implementation will further erode earnings and
capital creating additional risk to the health and vitality of community
banks.
• The assumptions by regulators are to general and broad based.
Consideration of the banks historical problems, geographic location,
management and capital should also be made part of the equation. Putting all
CRE into one bucket for entire US does not address concerns.
Kay Riebold, Executive Assistant, Bank of Whitman
S 201 Main/PO Box 270, Colfax, WA 99111
509-397-4629, 509-397-4954 FAX
