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Stockton National BankApril 14, 2005
Public Information Room
Office of the Comptroller of the Currency
250 E Street, SW, Mailstop 1-5
Washington, DC 20219
Attention: Docket 05-01I truly believe that this letter is a complete waste of my time. I do not believe that the regulatory agencies are enthusiastically behind the issue of reducing regulatory burdens. At the same time that the agencies are proposing to reduce our burdens they are creating regulatory burdens at a faster pace than ever before. The 0CC issued over 50 Bulletins last year. On top of that are all the "interpretations" made by 0CC personnel that are not disclosed to banks until an examination occurs.
Half of the problem with smaller banks is understanding what the regulations require. The OCC makes absolutely no effort to help banks understand what is required by the vast and complex web of regulations. It is slow to answer letters, if they are answered at all. When banks are relegated to writing letters to clarify parts of regulations, it should be abundantly clear that there is little communication from the 0CC down to banks. If the 0CC were rated as banks are rated during examinations, I would venture that the 0CC' would get a "needs improvement" at the very least and probably much worse.
We bankers are stressed-out and frustrated with the quantity and complexity of regulations. A little tinkering around the corners as you are proposing is not going to have any meaningful impact on our daily lives out here. John A. Berkley
|Last Updated 02/28/2005||Regs@fdic.gov|