PEOPLES STATE BANK
From: Tom Riherd Sent: Monday, July 26, 2004 12:43 PM To: Comments Subject: FIL-74-2004 / Proposed changes to FDIC Assessment Certified Statement Rule Dear FDIC – I agree with your decision not to require signed copies of the certifications to be returned to the FDIC if there are no changes, which in my years of experience, there have been none. The old requirement results in extra work for the bank and for your staff. However, with respect to requiring banks to download the report from the Internet site, I disagree with the proposal for the following reasons: 1. It would require someone to remember or schedule the activity of obtaining the certification quarterly. This can be forgotten by some employees, or the requirement no longer known to the bank in the case of turnover. I think that many banks will not receive the certification every single quarter if this requirement is made. 2. The action of mailing the certification to all the banks by the FDIC would require far less manpower than that required by thousands of banks to retrieve it from the Internet. For the banking system as a whole, this requirement will not be cost effective. 3. Many governmental websites are simply a “hassle” to use and often it takes a considerable amount of time to retrieve reports from websites that are used irregularly (i.e. quarterly). The usernames and passwords for rarely used sites are often forgotten which requires more effort to have new or replacement usernames and passwords issued by the FDIC. Doing this for a large number of banks could well offset any time/effort savings that the FDIC is anticipating. 4. The certification presently is routed directly to the President of most banks when it is received. If obtaining it from a website is required, the activity will likely be performed by lower level employees who will simply file the report away and it is likely that many bank presidents will never see the report again. Although the FDIC probably desires that the CEO’s see the reports, the fact remains that many bank CEO’s aren’t technically inclined and are not going to personally retrieve the certification each quarter. 5. At our bank, the certification is often included in the Board member information. Most Internet printouts are not as neatly reproducible and generally contain extraneous headers, footers, ect. Which would likely expand the certification from a 2-page report to a 3-4 page printout that is not nearly as attractively displayed. 6. Unless the report was provided in a secure format, such as Adobe Acrobat, it would be possible for someone to manipulate the appearance or content of the certification before showing it to others. Obviously, this would not change the bank’s classification with the FDIC, but it might allow an unscrupulous individual to mislead executive management or the board with respect to their capital or regulatory positions. 7. It would be just as efficient, if not more efficient, to e-mail the certification to a bank’s president with a 2nd copy to be e-mailed to the individual responsible for compiling the Call Reports. Thomas M. Riherd, II Vice President / Chief Financial Officer Peoples State Bank Lake City, FL |