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FDIC Federal Register Citations

Southern State Bancshares, Inc.

From: Don Walsh []
Sent: Tuesday, May 24, 2005 11:15 AM
To: Comments
Subject: comments FL-22-2005

Mr. Robert E. Feldman
FDIC Executive Secretary
550 17th Street, NW
Washington, DC. 20429

Re: Interagency Proposal of Classification of Commercial Credit Exposures

Dear Mr. Feldman:

As president of a small bank in South Arkansas, I am writing to express my opposition to the above proposal. We have a saying " If it ain't broke, don"t fix it". I think this applies in the case of loan classification. What problems have arisen requiring the change? As a small bank trying to survive the regulatory "crush" already, my opposition is based on the following:

A. The proposed system will be more complex and more burdensome on
small banks, as myself.

B. The regulators, State and FDIC, and the bankers have developed a
common vocabulary and understanding of terminology.
Why change it and confuse everyone?

C. Again, what is the big problem requiring the change?

D. If a change is necessary, my use the "one size fits all"
approach? Why not propose a large bank- $1 billion dollar or higher

Thank you for your consideration of my views in on this issue.


Donald Walsh
Pres. & Chairman
Southern State Bancshares, Inc.

Last Updated 05/25/2005

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