FDIC Federal Register Citations

From: Harwell, Tom
Sent: Tuesday, February 12, 2008 2:46 PM
To: Comments
Subject: Consolidated Reports of Condition and Income, 3064-0052

We have been anticipating the final requirements for the quarterly reporting that has been announce but not finalized. I see that the comment period has been opened again and requires submission by or before March 5, 2008. The original date required for reporting is March 31, (first quarter). This is too short of a time frame to allow the computer software to be upgraded. In reviewing the requirements June 30 is also to short of timeframe to make these upgrades and test for accuracy. By not allowing the time needed to properly make these changes we run the risk of not doing a complete upgrade requiring our clients to perform manual work which could result in inaccuracies.

On January 10, 2008, we were notified by the FDIC that the anticipated date for delivery of the final requirements would be the middle of January 2008, this did not happen. If it had it still would not have been enough notice to deliver for the March quarter end.

Please consider an effective date of third quarter ending.

Thanks you

Tom Harwell
Vice President, Regulatory Compliance
Fiserv Lending Solutions
South Bend, IN 46628-4320