From: Don Walsh [mailto:dwalsh@southernstatebank.com]
Sent: Tuesday, May 24, 2005 11:15 AM
To: Comments
Subject: comments FL-22-2005
Mr. Robert E. Feldman
FDIC Executive Secretary
550 17th Street, NW
Washington, DC. 20429
Re: Interagency Proposal of Classification of Commercial Credit Exposures
Dear Mr. Feldman:
As president of a small bank in South Arkansas, I am writing to express my opposition to the above proposal. We have a saying " If it ain't broke, don"t fix it". I think this applies in the case of loan classification. What problems have arisen requiring the change? As a small bank trying to survive the regulatory "crush" already, my opposition is based on the following:
A. The proposed system will be more complex and more burdensome on
small banks, as myself.
B. The regulators, State and FDIC, and the bankers have developed a
common vocabulary and understanding of terminology.
Why change it and confuse everyone?
C. Again, what is the big problem requiring the change?
D. If a change is necessary, my use the "one size fits all"
approach? Why not propose a large bank- $1 billion dollar or higher
theshold?
Thank you for your consideration of my views in on this issue.
Sincerly,
Donald Walsh
Pres. & Chairman
Southern State Bancshares, Inc.