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FDIC Federal Register Citations Durand State Bank
From: D.E. "Mac" Camac [mailto:dcamac@durandstatebank.com]
Sent: Friday, September 30, 2005 5:15 PM To: Comments Subject: Consolidated Reports of Condition and Income, 3064-0052 I echo the comments of Ms. Pagan and Mr. Barrett. In our 70 million
dollar bank I am the "staff" that completes the call report and even using
advanced software, the best I can hope for in completing the report is 3
to 4 days. We have spent years booking loans into our core processor software not
having to identify those factors that it will be necessary to identify in
order to accommodate the Construction Loans breakout and the Non-Farm
Non-Residential Loans breakout. As has been pointed out, we will now have
to add two more layers of identification, which if only applied to future
loans would not be too difficult. But to have to essentially go through
every loan file to see if the new codes should be applied to any given
existing loan will be exceedingly onerous. I suppose that "net increase of
1.79 hours" would be a reasonable figure if the intitial time investment
was spread over the rest of my natural life, but I think it reasonable to
assume that before the time to effect these changes has been "expensed"
out, we will certainly see another set of additions of information that
somebody just absolutely has to know. I find that reducing regulatory burden is like changing the weather.
Everybody talks about it, but nobody really does it. Mr. Barrett is
correct in asserting that substantially less, or certainly more
consolidated, information would suffice to measure risk in small community
banks. I find it interesting that those who think these are wonderful ideas
are not those who have to face the burden of completing the report. D.E. CAMAC
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Last Updated 10/03/2005 | Regs@fdic.gov |