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FDIC Federal Register Citations

From: Robert Barnes []
Sent: Tuesday, June 07, 2005 11:32 AM
To: Comments
Subject: FW: Proposed Changes to Loan Classifications

Dear Sir or Madam:
I am opposed to the proposed changes to loan classifications for the following reasons:

1. The proposed system will be more complex and more burdensome on
the smaller institutions. 

2. The regulators and the bankers have developed a common vocabulary and understanding
of terminology. I see no need to change our vocabulary and confuse everyone involved.

3. I question whether there is a big enough problem with the rating disparities to
require a completely new rating system.

4. Why should the proposal apply to all banks? Why not propose a
threshold of $1 billion or higher?


Robert J. Barnes, Chief Credit Officer


Last Updated 06/08/2005

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