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Federal Deposit
Insurance Corporation

Each depositor insured to at least $250,000 per insured bank

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FDIC Federal Register Citations

Premier Bank
From: Wade Gort
Sent: Friday, June 17, 2005 9:50 AM
To: Comments
Subject: Proposed classification changes

Good Morning Mr. Feldman:

This email is in response to the Agency’s proposed changes to the current classification system.  Your proposed changes are not necessary and appear to more subjective than they are now.  We already in our Quarterly Watch List Report to our Board of Directors analyze our risk and estimate our loss exposure based upon our knowledge of our collateral and borrower’s capacity and willingness to repay their obligations.  This change would be very costly to community banks and appears to be not necessary.  I believe history shows that almost all bank failures and therefore risks to the Insurance Fund come from poor management decisions that this classification system would not change or improve one bit.  It would appear that most bank failures today arise from fraud or greed or a combination of both.  I can also foresee a great deal of examiner vs. banker debate over the amount of loss potential in a certain line of credit and assigning a rating based upon the amount of loss expected.  The current system for our bank is not broken and we do not see any benefit for us to change.  Therefore we request that you do not adopt this proposal and leave what isn’t broken alone.


Wade Gort
President & CEO
Premier Bank
P.O. Box 177
Rock Valley, IA  51247

Last Updated 06/21/2005

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