From: Doug Keipper [mailto:dkeipper@thepeachtreebank.com]
Sent: Monday, April 12, 2004 11:55 AM
To: 'regs.comments@federalreserve.gov'; Comments; 'regs.comments@occ.treas.gov';
'regs.comments@ots.treas.gov'
Subject: Regulation burdens
To whom it may concern,
I'm getting emails that you want some feedback on regulations.
Here is my
2 cents.
With foreclosure rates at an all time high what are your thoughts
on our
lending practices?
I propose that we can eliminate HMDA - we are obviously approving
too many
borderline loans just to prevent "lawsuits" and what
does it do to our
profitability and return on investment for the shareholders? We're
losing
money approving borderline loans just to prevent lawsuits. Why
don't back
profitability as a priority.
If our loan to deposit ration is above 90% why do CRA reports?
We are
obviously making the loans.
Reduce the CTR exemption to 6 months.
Streamline the document retention period to 5 years. Make everything
the
same. EVERYTHING.
I just filed a warrant for an arrest of a customer who is hiding
his past
due car. The warrant asks for race, distinguishing facial scars,
mustache
or beard, all the stuff we can't notate during the loan phase.
If we put
the drivers license copy in the file we get accused of discrimination.
Keeping separate files is ridiculous. Let us keep the drivers license
in
the file.
Keeping a 1% loan loss reserve on a loan that is less than 90 days
old is
killing our profitability during our growth stage. We put a loan
on the
books and before we can collect any interest we have to put money
into a
loan loss reserve. It takes 90 days for the loan to go bad. Let
us put
the 1% loan loss on at the 90 day mark. Let us collect some interest
to
fund the loan loss reserve.
Those are my thoughts.
Doug Keipper
The Peachtree Bank
9570 Medlock Bridge Rd
Duluth, GA 30097
