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FDIC Federal Register Citations

Durand State Bank
 
From: D.E. "Mac" Camac [mailto:dcamac@durandstatebank.com]
Sent: Friday, September 30, 2005 5:15 PM
To: Comments
Subject: Consolidated Reports of Condition and Income, 3064-0052

I echo the comments of Ms. Pagan and Mr. Barrett. In our 70 million dollar bank I am the "staff" that completes the call report and even using advanced software, the best I can hope for in completing the report is 3 to 4 days.

We have spent years booking loans into our core processor software not having to identify those factors that it will be necessary to identify in order to accommodate the Construction Loans breakout and the Non-Farm Non-Residential Loans breakout. As has been pointed out, we will now have to add two more layers of identification, which if only applied to future loans would not be too difficult. But to have to essentially go through every loan file to see if the new codes should be applied to any given existing loan will be exceedingly onerous. I suppose that "net increase of 1.79 hours" would be a reasonable figure if the intitial time investment was spread over the rest of my natural life, but I think it reasonable to assume that before the time to effect these changes has been "expensed" out, we will certainly see another set of additions of information that somebody just absolutely has to know.

I find that reducing regulatory burden is like changing the weather. Everybody talks about it, but nobody really does it. Mr. Barrett is correct in asserting that substantially less, or certainly more consolidated, information would suffice to measure risk in small community banks.

I find it interesting that those who think these are wonderful ideas are not those who have to face the burden of completing the report.

D.E. CAMAC
Vice-President & IT Director
Durand State Bank
Durand, Illinois



Last Updated 10/03/2005 Regs@fdic.gov

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