From: Thurlow, Julie [mailto:jthurlow@readingcoop.com]
Sent: Tuesday, March 29, 2005 12:59 PM
To: Comments
Subject: FIL-22-2005 Classification of Commercial Credit Exposures
To Whom It May Concern;
This writer is opposed to modification of the current commercial loan classification categories for the following reasons;
1. The current classifications have served the institution adequately
2. The current classifications integrate well with our current Loan Loss Reserve Calculations
3. The recommended change builds a second distinct category which cannot be supported by current software framework.
4. Having two divergent measurements and attempting to map institution measures to regulatory measures will result in confusion and misinterpretation
5. There is no rationale present to justify a change in current measurements
6. This proposal serves as merely a modification requiring additional effort by banks with no reward.
7. The Accounting profession requires full justification of the loan loss reserve, both specific and general that already meets the goal of this proposal
As a banker in a small community bank, the volume of guidance, new interpretations, recommended policies and procedures, and supervisory changes having minimal impact on the actual business of banking and no benefit to consumers as a whole have become an impediment to the industry.
New business development hours continue to be cut back as time is spent rewriting policies. The policy and procedure changes proposed have no beneficial effect on safety and soundness, on profitability and capital.
The proposal should not be advanced until the FDIC can answer the question of “Why” it is necessary and what the benefit it provides the industry.
If you have any questions, or wish to discuss the above, please do not hesitate to contact me at (781) 942-5008, ext 108.
Yours truly,
Julieann M. Thurlow
Senior Vice President