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FDIC Federal Register Citations
Mohave State Bank

From: Ralph Tapscott  
Sent: Friday, April 22, 2005 12:01 PM
To:; Comments;;
Subject: EGRPRA

I compliment your desire to receive input from the industry being impacted.
First off, I believe a compliment is due to the various regulatory bodies
for assisting in the maintenance of the strongest banking industry in the
world.  I also realize that many of the agencies are hard-pressed to
maintain adequate staffing levels to support the continued layering of new
legislative mandates.

Perhaps my motivation for responding is a little self-serving, but I am
compelled to address one small issue.  The frequency of safety and soundness
exams for banks that are considered "well rated".  We are a state chartered
bank with joint supervision by the Arizona State Banking Department and the
FDIC.  We have established a good working relationship with both regulatory
agencies.  Our bank has and has had favorable regulatory reviews over the
past decade.  We are a fairly "vanilla" type bank, and we do not engage in
any significant high-risk activities.  The biggest concern we have at this
time, like many banks in the West, is a concentration in commercial real
estate.  We mitigate this risk with officer training, the maintenance of a
high allowance for loan and lease loss, and maintaining adequate capital -
to name a few.

I would like to see exam cycle stretched to 18 - 24 months for banks that
have historically exhibited sound banking practices.  The various regulatory
bodies do review interim data, they conduct informal management reviews, and
they could always expedite a review cycle if they deemed more than average
risk exists.  Allowing an 18 - 24 month cycle, as opposed to a 12-month exam
cycle, would allow well run banks to continue their focus of being well run

Thanks for giving me the opportunity to provide my feedback.

Ralph E. Tapscott
President & CEO
Mohave State Bank

Last Updated 04/25/2005

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