Federal Deposit
Insurance Corporation

From: Liz Hodge [mailto:Liz@omnibk.com]
Sent: Thursday, April 13, 2006 8:25 PM
To: Comments
Subject: 2006-01 - Commercial Real Estate Lending, Sound Risk MgtPractices--01/13/06
Real estate loan concentration does not, in and of itself, indicate high risk lending. The risk is in inadequate control and oversight.

Banks that meet or exceed high-level Risk Management Profiles, as defined by regulators, have already implemented appropriate controls, which should prevent the unnecessary need for increased capital.

High risk banks without the appropriate control structure should be dealt with by examiners on a case-by-case basis, using appropriate enforcement tools.

Thank you for the opportunity to respond to the CRE proposal.

Elizabeth Hodge
Vice-President, Compliance
OMNI BANK
Metairie, LA