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Community Bank & Trust
From: Steve Hoag [mailto:email@example.com]
June 15, 2005
Dear Mr. Feldman:
I am writing to express my strong opposition to the proposal that the
FDIC is considering in regard to revising the classification system for
commercial credit exposures. Since 1938, the current classification system
has worked well and has served financial institutions adequately. As an
ex-OCC bank examiner, my opinion is that the classifications utilized by
examiners are more than adequate and do not need revising.
The current classifications integrate well with our current loan loss
reserve calculations. Our current software would not support the
recommended changes without additional expenses that will be very hard to
justify as there is no rationale present to justify a change. This
proposal serves as merely a modification requiring additional effort by
banks with no rewards and does not appear to provide any significant
improvements to the current classification methodology. The current system
is a proven and well tested tool that is highly recognized, easily
understood and fully integrated into the banking industry by regulators,
external auditors, and bankers.
While I can not express an opinion on how these changes might help
those publicly held institutions with assets more than one billion
dollars, I strongly oppose the agencies enforcing this change to smaller
institutions, especially privately held community banks, with less than a
billion dollars in assets.
This proposal should not be implemented. Additionally, I would like to
see the deadline for the comment period extended past June 30, 2005, to
allow for additional input.
If you have any questions, or wish to discuss this matter further,
please do not hesitate to contact me at 254.399.6155
Steve Hoag, Jr.
|Last Updated 06/17/2005||Regs@fdic.gov|