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Community Bank & Trust
Mr. Robert E. Feldman
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.
Mark A. Boyd
Letters will be sent to the following:
Central National Bank
First National Bank of Central Texas
Clyde D. Martin
Texas First State Bank
American Bank, N.A.
D. Allan Morris
J. Mark Gibson
Nnora Thompson, SVP
Rogers Pope, Jr.
Monty Rogers, SVP
Cynthia Sheffield, SVP
Barry J. Haag, President
|Last Updated 06/24/2005||Regs@fdic.gov|