FDIC Federal Register Citations

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50.

Dear Sir;

For the 1st time in over 30 years as a commercial banker I am finally compelled to submit a complaint about over regulation. On a daily basis I observe staff members struggling with a long list of compliance issues that have become so unwieldy that I wonder how we accomplish anything at all in this country. I am supposed to be suggesting to you that the threshold for compliance be increased so that only the bigger banks have to comply. I have a hard time with that. The truth is that all banks need relief!

The effort that it takes to approve a loan and get the funds into the borrowers hands is unbelievable today. The struggle to properly classify the loan, report the correct amount of income used to make the loan decision and to complete all of the internal forms required to prove to your organization that we are not criminals intent upon cheating the underprivileged or assisting a subversive or laundering dirty money is frankly overwhelming and borders on the insane.

I may be fortunate enough to retire within the next ten years but I am very concerned that the commercial banking system will not survive. The young bankers may be better equipped to deal with the bureaucracy, but I think the smart ones will opt out. The credit unions, who can afford to cope with the added expense (since they are not taxed), will be assuming our role someday and then you will have the same problems with them.

I am beginning to believe what the foreigners say about us. Give us something good and it will only be a matter of time before we break it, lose it or pollute it. I believe the commercial banking system has become polluted with so much regulation that it is beyond repair. Please do something about that.

Yours truly,

John Brittain
Vice President
South Valley Bank and Trust