From: Linda A. Ramón [lramon@fsbuvalde.com]
Sent: Thursday, April 21, 2005
To: Comments
Subject: FIL-22-2005 Proposed Classification of Commercial Credit Exposures
To Whom It May Concern:
We are opposed to the proposal because it does not appear to provide any significant improvement to the current classification methodology. The current system is a proven and well tested tool that is highly recognized, easily understood and fully integrated into the banking industry by regulators, external auditors and bankers. The proposal, on the other hand, is complex and confusing and will require many man hours to change policies, procedures, and internal reports and will be nothing more than an added burden to bankers, in particular, small independent banks while accomplishing little benefit, if any, to an already more than adequate classification system.
The regulatory burden heaped on bankers is more than enough to contend with and affords community bankers less and less time to spend on more important matters such as business development and combating loss of market share. We are not in agreement with the proposal and suggest that the regulators not try to "fix" something that is not "broke".
Regards,
Linda A. Ramón/Vice President/Loan Review Officer/Compliance Officer
First State Bank of Uvalde
Uvalde, Texas