Federal Deposit
Insurance Corporation

Our company, Fiserv, Lending Solutions Division, provides automated services for over 70 banks, saving banks, mortgage lenders, etc. I have had conversations with some of them concerning these proposed changes and I am leaving the detail comments to them, the experts. However, I would like to make one request and that is, we need more time to update our system than the time we are normally given. Today’s financial computer programs are extremely complicated, much more so that 20 or 30 years ago when we were able to update our programs in 30 days or more depending on the complexity of the change. Today our normal cycle to design, program, test and install a medium to large change is 9 months. This is because our systems have grown so much due to State and Federal regulations, investor requirements, consumer protection, etc. that any change can affect many parts of the system therefore requiring extensive research in the design and also extensive testing. Naturally, there is a process to expedite smaller changes in a much less time frame. From my experience and association with our competitors I feel that this is a universal issue, especially with service providers like Fiserv. By giving us more time to comply with your requirements we can deliver a better product that will benefit both, our clients as well as the FDIC and other agencies.

Thank you for the time to consider my request.

Tom Harwell
Vice President, Regulatory Compliance
Fiserv Lending Solutions
3575 Moreau Court Drive
South Bend, IN