FDIC Federal Register Citations

BankFirst

From: Debbie Kirk [mailto:dkirk@bankfirstfs.com]
Sent: Wednesday, March 15, 2006 5:22 PM
To: Comments
Subject: Proposal on Concentrations in Commercial Real Estate Lending

From a community bank's view, as the CRE proposal is currently written, it would force smaller banks to considerably limit lending in these areas. This would result in less available credit for local communities which is definitely not our bank's objective or the objective of the Community Reinvestment Act.

As well as being time-consuming for community banks to comply with the proposal, the costs of compliance would be considerable. Additional information systems would have to be created, current coding systems upgraded, additional staff hired and loan monitoring increased. Not to mention increasing capital.

Based on the current proposal and the fact that our bank is above the percentages for both thresholds, we would be forced to sell loans currently on our books in order to reduce our exposure to this types of credit. We would also be forced to greatly decrease our lending in these areas.

The proposal, as written, is just not feasible for the community bank and is definitely detrimental to community banks and their local communities.

Sincerely,

Debbie Kirk
Vice President
BankFirst Financial Services
Macon, Mississippi 39341