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FDIC Federal Register Citations Century Bank From: Charlie Brown [mailto:charlie@centurybankms.com] Sent: Thursday, June 16, 2005 10:12 AM To: Comments Subject:
I am writing about the proposed changes in
the method to reserve for loan and lease losses. The proposed changes
will impose a burden on small banks that will be difficult to shoulder
and larger banks will be no better off with the new system, nor will
the public.
Assigning a risk rating to each loan is
overkill and will cause much confusion. Bankers and regulators
understand the present system and it has served us well for a long
time.
The biggest harm that I see coming from
the proposed changes is that the regulators, the ones whose charge it
is to see that banks maintain sound reserves, will recommend lowering
loss reserves in banks that have more than the calculated reserve.
The banks that made it through the great
depression were banks that had more than adequate capital and
reserves. They were conservative and prudent and had reserves stuck
away for a rainy day. The proposed changes, if I understand them
correctly, would not allow a bank to reserve more than the calculated
amount. These changes would discourage bankers from being
conservative.
These changes, if implemented, will be a
nightmare for both regulators and bankers and will serve to undermine
our entire system of banking. The system in place now has worked and
worked well for a long time. Don't try and fix it because it is not
broken.
Sincerely,
Charles F. Brown III
Ex. V.P.
Century Bank
P. O. Box 647
Lucedale, Ms, 39452
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Last Updated 06/17/2005 | Regs@fdic.gov |