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FDIC Federal Register Citations BankFirst Financial Services From: Debbie Kirk [mailto:dkirk@bankfirstfs.com] The proposed Commercial Real Estate Lending (CRE) regulation would
unfairly target community banks. This proposal would be extremely costly and
burdensome to the community bank, and would leave our bank with no choice
other than to drastically reduce our CRE lending. We believe we already have good risk management practices in place to
monitor CRE lending. Proposed guidance is unneccessary. Real estate
standards and guidelines are already in place and are enforced by examiners
with every exam. All of our banks are located in counties recently affected by Hurricane
Katrina. As a result of this disaster, over the next five to ten years,
there will be the necessity for many rebuilding projects in these disaster
areas. All of these projects will fall under the CRE regulation as proposed.
Banks located in these areas designated as disaster counties certainly
should be exempt from any new regulation concerning commercial real estate
lending. Jerry T. Wilson
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Last Updated 03/28/2006 | Regs@fdic.gov |