Federal Deposit
Insurance Corporation

I am writing to express my opposition to the proposal that the FDIC is considering in regard to revising the classification system for commercial credit exposures.  I believe that there will be no significant improvement in risk management through implementing these changes.  Such a change would simply cause an increased burden on small banks through the costs to modify computer software, train staff, etc.  The current classification methodology has worked well for decades and has served financial institutions adequately.  Further, 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. 

As an officer of a relatively small, locally-owned bank, I see no potential benefit to such a change that would subject small banks to additional expenses for implementation. 

This proposed change should not be implemented.  Additionally, the deadline for the comment period should be extended past June 30, 2005 to allow for more input. 

I would welcome a call from you to discuss this matter further.  Thank you. 

Sloan Kuehl
Vice President
First National Bank of Central Texas