Federal Deposit
Insurance Corporation

Re: Proposed Guidance- Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices - 71 FR 2302 (January 13, 2006)

Dear Sir or Madam:

America’s Community Bankers (ACB)1 appreciates the opportunity to comment on the Proposed Guidance –Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices2 (“Proposed Guidance”) issued by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of Thrift Supervision (collectively, the “Agencies”).

ACB urges the Agencies to extend the March 14, 2006 due date for comments on the Proposed Guidance by 30 days. The Proposed Guidance was published in the Federal Register on January 13, 2006 and we believe an extension would be beneficial for all parties.

The proposal is extremely complex and has far-reaching consequences for our members, as well as for the nation’s mortgage markets. We believe that it will take an additional 30 days to complete the necessary evaluation and collect comments and data from our membership. A 30-day extension would enable our association to provide the Agencies with the most meaningful comments on the Proposed Guidance.

For these reasons, we request that the Agencies extend the comment period on the Proposed Guidance to April 13, 2006. We appreciate your consideration of the requested extension and urge you to make a determination as quickly as possible.

Sincerely,