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FDIC Federal Register Citations American Bank of Commerce From: pkelly@theabcbank.com [mailto:pkelly@theabcbank.com] RE: call for comment Docket No. 06-1 Dear Sirs: In an ever changing market we are aware of the volatile real estate environment. As a banking institution we make numerous commercial real estate loans and we are very aware that we must have good underwriting guidelines and monitor the loan portfolio on a regular basis for weaknesses and risk. That being said, we are also a growing community bank and feel that this proposal would make it very prohibitive for us to compete with the larger institutions and push us out of the market. The "concentrations" thresholds and higher capital requirements seem to make it unfair for us to compete for the business especially since (we feel that) we are adequately capitalized under the current ratio guidelines. As in other areas, it would be best to suggest a fair way to put this into practice (if you must!). Divisions of small, intermediate and large should be considered and ability of each should be reviewed. A large bank would have no issues with the IT reporting/tracking but it would be a burdensome matter for our size of institution in costs and manpower. We are aware of our markets, we lending accordingly taking all factors and risks into mind. You, the regulators, have sufficient guidance already in place to monitor us in this regard. Please help to make it more conducive for us to continue or commercial real estate lending and not more prohibitive for us to do business. Thank you for allowing us the opportunity to comment; a large portion of our portfolio is in commercial real estate and feel that we would be adversely affected by this proposal. Best Regards,
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Last Updated 04/18/2006 | Regs@fdic.gov |
