Federal Deposit
Insurance Corporation

Our bank is not in favor of this change. We are a $60 million dollar independent bank and see no advantage, and in fact will have to rely on manual, rather than automated functions to accomplish what you are recommending.

To single out “Commercial Loans” would mean we would have two systems, one for Commercial and one for Consumer, adding to the confusion.

The present system is quite adequate and has served the small banks well. Please don’t cause us addition time, money, and an opportunity to make manual mistakes in a dual adequacy system.

Greg N. Walters, EVP
Citadel Bank