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FDIC Federal Register Citations The Monitor Bank From: Joe Wachtel [mailto:joe@monitorbank.com] While there may be benefits in some of the changes, others just create
more work and have nothing to do with safety and soundness ... for example,
splitting "construction, land development, and other land loans" and
splitting "nonfarm nonresidential properties". This seems to follow the
ever-growing mentality of the regulators that bankers are just a bunch of
bumbling idiots who couldn't open the doors of their banks without advise
from the regulators. Also, the revised director attestation indicating that
signing directors have reviewed the report is ridiculous. No one just
"reviews" a call report. All supporting documents must be reviewed and a
thorough understanding of the report is a must. This would realistically
require hours of time for the review, with continuing education for what are
part-time directors holding down other jobs or running their own business.
This would be the same as regulators understanding all the sophisticated
documents and reports of the businesses the directors are involved in -
impossible at best. Joe Wachtel - President |
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Last Updated 10/11/2005 | Regs@fdic.gov |