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FDIC Federal Register Citations Alma Exchange Bank From: Rod Rentz [mailto:rodr@almaexchangebank.com] Robert E. Feldman Dear Mr. Feldman: Concerning the guidance on commercial real estate lending being proposed by th FDIC, I would like to offer some comments. My understanding is that if our bank has commercial real estate loans totaling more that the concentrations levels in the guidance, we may be required to hold a higher level of capital and institute what may be burdensome risk monitoring controls. I feel that there already exists an adequate body of real estate lending standards, regulations, and guidelines. Examiners already have the necessary tools to enforce them and address unsafe and unsound practices; the proposed guidance is unnecessary. Addressing CRE management problems bank by bank seems a more prudent approach. The proposed threshold limits of CRE loans to capital are too restrictive and do not take into account the lending and risk management practices of individual institutions. They also do not recognize that different segments of the CRE markets have different levels of risk. Our bank already holds capital at levels above minimum standards and should not need to raise additional capital because our CRE loans exceed the proposed thresholds. The bank’s allowance for loan losses and current capital levels along with risk management practices should be the primary criteria used by regulators. Thank you for your consideration of these comments. Sincerely, | ||
| Last Updated 04/17/2006 | Regs@fdic.gov | |