NorthSide Community Bank
From: Bill Kivit
Sent: Saturday, January 21, 2006 11:22 AM
To: Comments
Subject: Community Banks
By increasing the level of capital required and regulations for community banks involved in commercial real estate lending, the FDIC will restrict competition and penalize the very core business that community banks thrive on. A more practical approach would be to review the quality of the loan portfolio and amount of loan loss reserve carried. A generic approach requiring greater capital requirements penalizes community banks that underwrite sound loans and does not address the issue of poor underwriting. Poor underwriting will always result in loan losses, despite the level of capital or regulation. As a result, the problem should be addressed specifically. A shot gun approach will not limit commercial real estate loan losses.
Bill Kivit
Vice President
NorthSide Community Bank
Contact: Regs@fdic.gov