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FDIC Federal Register Citations

The Peoples Bank

June 29, 2005

The Peoples Bank
P.O. Box 340
Magnolia, AR 71754-0340

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

RE: Interagency Proposal on the Classification of Commercial Credit Exposures

Dear Mr. Feldman,

On behalf of the directors, officers, and shareholders of Peoples Bank, I make the following commentary regarding the request for public comment on the above listed interagency proposal.

We strongly believe the proposed system will be more complex, and more burdensome than the present system. This is especially concerning to us due to the amount of regulatory burden we experience as a small, community bank.

The current system works extremely well in small banks in our state and region, and therefore is not believed to possess any areas of improvement in risk measurement. To us, if risk measurement needs to be strengthened it would make more sense to add complexity in large institutions ($1 billion and more) or in institutions that engage in activities that could be argued to require a more comprehensive rating scale.

The regulatory burden we as a small bank presently experience is heavy. For small banks such as ours to compete in the marketplace, and continue to be stable employers and economic catalysts, we must not be considered in the same light as large banks. We urge you and your staff to do all that you can to prevent this proposal from being applied to small banks.


Todd D. Smith
The Peoples Bank
Magnolia, Arkansas
respond to:

copy: Scott N. White, EVP and Chief Credit Officer
The Peoples Bank, Magnolia, Arkansas

Last Updated 06/30/2005

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