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FDIC Federal Register Citations
From: Forrester, Cameron [] 
Sent: Thursday, June 16, 2005 5:19 PM
To: Comments
Subject: Change in Classification Comments Below

June 16, 2005

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

RE:  Change in Classification of Loans OP-1227

Dear Mr. Feldman:

I am writing to express my opposition regarding the changes in commercial
loan classifications.  Should these changes occur the Borrower Rating and
Facility Ratings would be more complex and burdensome on the small banking
institutions.  The small banking regulators and bankers have developed a
common vocabulary and understanding of terminology.  A change in the
vocabulary and terminology would result in confusion to all involved.  The
question arises, if there is a big enough problem with the rating
disparities to require a new rating system.  Would it not be best to propose
a threshold for larger banks instead of applying this proposal to all banks?

Thank you for your time and consideration in this request.

Cameron L. Forrester
Senior Vice President & Chief Lending Officer

Last Updated 06/17/2005

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