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FDIC Federal Register Citations

1st Bank

January 17, 2006

Robert E. Feldman, Executive Secretary
ATTN: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

RE: FDIC RIN 3064-AC96

Risk-Based Capital Guidelines; Capital Adequacy Guidelines; Capital Maintenance: Domestic Capital Modifications

Dear Mr. Feldman:

I just read an article pertaining to the advance notice of proposed rulemaking (ANPR) addressing the risk-weighted capital requirements for banks.

I have made the observation, based on approximately 40 years of banking, that the banking rule-making bodies only have “one paintbrush and one bucket of paint.” All banks seem to have to abide by the same or similar regulations regardless of the following:

• the risk each size institution represents to the FDIC and the financial industry;
• the number of staff available, or lack thereof, to comply with regulations, including their competency;
• the cost to comply as a percent of assets, since assets produce the gross profit to cover overhead costs;
• if it is a rural bank or a metropolitan bank.

My point is this: Please make regulations that relate to the true risk that an institution’s size and geographic location present to the national financial industry.

Sincerely,

John L. Franklin
President & CEO


Last Updated 01/19/2006 Regs@fdic.gov

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