PEOPLES STATE BANK
From: Tom Riherd
Sent: Monday, July 26, 2004 12:43 PM
To: Comments
Subject: FIL-74-2004 / Proposed changes to FDIC Assessment Certified Statement
Rule
Dear FDIC –
I agree with your decision not to require signed copies of the certifications
to be returned to the FDIC if there are no changes, which in my years
of experience, there have been none. The old requirement results in extra
work for the bank and for your staff.
However, with respect to requiring banks to download the report from
the Internet site, I disagree with the proposal for the following reasons:
1. It would require someone to remember or schedule the activity of
obtaining the certification quarterly. This can be forgotten by some
employees, or the requirement no longer known to the bank in the case
of turnover. I think that many banks will not receive the certification
every single quarter if this requirement is made.
2. The action of mailing the certification to all the banks by the FDIC
would require far less manpower than that required by thousands of banks
to retrieve it from the Internet. For the banking system as a whole,
this requirement will not be cost effective.
3. Many governmental websites are simply a “hassle” to use
and often it takes a considerable amount of time to retrieve reports
from websites that are used irregularly (i.e. quarterly). The usernames
and passwords for rarely used sites are often forgotten which requires
more effort to have new or replacement usernames and passwords issued
by the FDIC. Doing this for a large number of banks could well offset
any time/effort savings that the FDIC is anticipating.
4. The certification presently is routed directly to the President of
most banks when it is received. If obtaining it from a website is required,
the activity will likely be performed by lower level employees who will
simply file the report away and it is likely that many bank presidents
will never see the report again. Although the FDIC probably desires that
the CEO’s see the reports, the fact remains that many bank CEO’s
aren’t technically inclined and are not going to personally retrieve
the certification each quarter.
5. At our bank, the certification is often included in the Board member
information. Most Internet printouts are not as neatly reproducible and
generally contain extraneous headers, footers, ect. Which would likely
expand the certification from a 2-page report to a 3-4 page printout
that is not nearly as attractively displayed.
6. Unless the report was provided in a secure format, such as Adobe Acrobat,
it would be possible for someone to manipulate the appearance or content
of the certification before showing it to others. Obviously, this would
not change the bank’s classification with the FDIC, but it might
allow an unscrupulous individual to mislead executive management or the
board with respect to their capital or regulatory positions.
7. It would be just as efficient, if not more efficient, to e-mail the
certification to a bank’s president with a 2nd copy to be e-mailed
to the individual responsible for compiling the Call Reports.
Thomas M. Riherd, II
Vice President / Chief Financial Officer
Peoples State Bank
Lake City, FL
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