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FDIC Federal Register Citations
Bank Star One

From: Paul Langewisch [mailto:p.langewisch@bank-star.com] 
Sent: Thursday, June 16, 2005 2:48 PM
To: Comments; regs.comments@federalreserve.gov
Subject: Docket Number OP-1227


Gentleman:  I attended the Conference of State Bank Supervisors and your
proposed regulation was a topic of a "breakout session". Needless to say,
the comments toward your proposal were very negative from the sample of
bankers in attendance.

As a lifelong Missouri banker, I feel this is a needless change and will not
help small and medium size banks.  Our loan officers are very familiar with
the credits and having this new system will not be of any help to us.  In
fact, if your law if passed, we will have to change our loan policies,
procudures, rewritting loan loss allowances and retraining personnel to make
the changes. This is all very costly for a bank of our size, which is
$86,000,000. We are already stressed in both personnel cost and compliance
stress with the laws already on the books and we do not need this proposed
change on top of what we already have.

One final note, if this proposal is needed, it should be restricted to the
largest, most complex banking organizations that you monitor.  We small
banks already bear over regulation regarding federal and state laws.  I see
no valid need for this commercial regulation for banks our size.

Sincerely,
Paul Langewisch
Bank Star One
Fulton, MO

Last Updated 06/17/2005 Regs@fdic.gov

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