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FDIC Federal Register Citations

Community Bank & Trust

June 13, 2005

Mr. Robert E. Feldman
Executive Secretary of FDIC
550 17th Street, Northwest
Washington, DC 20429

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.

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 banks, with less than a billion dollars in assets.

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

If you have any questions, or wish to discuss this matter further, please do not hesitate to contact me at 254.399.6159.

Yours truly,

Mark A. Boyd
Senior Vice President

Letters will be sent to the following:

Central National Bank
P. O. Box 2525
Waco, Texas 76702

Bill Nesbitt
David Smith
Carolyn Haferkamp

First National Bank of Central Texas
1835 North Valley Mills Drive
Waco, Texas 76710

Clyde D. Martin
Monte Hulse
Ricky Thompson
Sloan Kuehl
Brian Hand (Mart)

Texas First State Bank
4900 Sanger Avenue
Waco, Texas 76710

Rodney Kroll
Brian Aycock
John Low
Parker Boyd (Gatesville)

American Bank, N.A.
P. O. Box 2507
Waco, Texas 76702

Willard Still
Tracy Slaughter
Sharon Wise

Extraco Banks, N.A.
1700 North Valley Mills Drive
Waco, Texas 76714

D. Allan Morris
Mark Reynolds
Fidelity Bank of Texas
P. O. Box 5540
Waco, Texas 76708

Todd Moore
Scott Rogers
First National Bank Bosque County
P. O. Box 278
Valley Mills, Texas 76689

J. Mark Gibson
John Gilliam
Synergy Bank
510 North Valley Mills Drive #100
Waco, Texas 76710

Dana Hassell
Citizens National Bank in Waxahachie
P. O. Box 717
Waxahachie, Texas 75168

Cindy Smith
Mark Singleton
NBC Bank
13401 North Pennsylvania
Oklahoma City, Oklahoma 73120

Jim Talkington
SWGSB banks to send letters to

Mary Winikates, VP
Propser State Bank
P. O. Box 10
Prosper, Texas 75078

Nnora Thompson, SVP
First National Bank of Bryan
P. O. Box 833
Bryan, Texas 77805

Rogers Pope, Jr.
Texas Bank & Trust
P. O. Box 3188
Longview, Texas 75606

Monty Rogers, SVP
Wayne Schroeder, SVP
Michael Edmiston, VP
Security State Bank,
P. O. Box 7197
Odessa, Texas 79760

Cynthia Sheffield, SVP
First National Bank of Livingston
P. O. Box 671
Livingston, Texas 77351-0671

Barry J. Haag, President
First Texas Bank
P. O. Box 649
Georgetown, Texas 78627

Debra Lawrence
Citizens National Bank
P. O. Box 269
Teague, Texas 75860

Michael Cope
The Commercial Bank
P. O. Box 40
Mason, Texas 76856


Last Updated 06/24/2005

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