Federal Deposit
Insurance Corporation

From: Linda Dillon [mailto:Linda.Dillon@banksbc.com]
Sent: Friday, April 14, 2006 4:00 PM
To: Comments
Subject: Proposed Interagency Guidelines on Concentrations in Commercial Real Estate

Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

The State Bank of Countryside is an independent, family-owned bank that has been serving the Chicagoland community for over 31 years. The Bank has assets totaling 1 billion dollars and specializes in all aspects of real estate lending.

The Bank has implemented many of the procedures outlined in the Proposal. The few that remain outstanding will be implemented in the near future. In fact, it is a measure of how seriously the Bank takes these procedures that we implemented many of them some time ago prior to the publication of the Guidance Proposal.

We, the members of the State Bank of Countryside and its Board of Directors, write this letter in support of the American Bankers Association’s position on the recommendations set forth in the Guidance Proposal. Like the ABA, we believe that the Proposal contains much of value. However, certain components of the Proposal would impose an undue burden on most community banks. Sound risk management practices along with strong policies and procedures take precedence over the "one size fits all" philosophy as put forth by the Proposal.

In conclusion, we strongly support the ABA’s position and yet recognize many of the agencies recommendations as a means of further improvement. However, the Proposal needs further discussion in its present form.

Thank you for the opportunity to express our view and opinion.

Sincerely,
Thomas P. Boyle, President
State Bank of Countryside
6734 Joliet Road
Countryside, IL 60525