Federal Deposit
Insurance Corporation

From: David A. Jones [mailto:dajones@grinnellbank.com]
Sent: Thursday, June 23, 2005 1:06 PM
To: Comments
Subject: Comment on FIL-22-2005

Re: FIL-22-2005, March 28, 2005
Classification of Commercial Credit Exposures

Comment; June 23, 2005

It appears the ‘Borrower Ratings” of Marginal, Weak and Default are very comparable to the system currently in place of Substandard, Doubtful and Loss. To require everyone to be retrained and have to rewrite policies and rules, does not appear to create a benefit.

The idea to add a system to measure the hard dollar loss potential is a good one and is understandable. Adding the “Facility Ratings” system to identify potential hard dollar costs has merit. Although, it appears this could be done without replacing the “Borrower Ratings” system in place. Adding to it, would be more cost justifiable and would not require the large amount of work and expense of totally scraping the system and installing a new one.

The cost & burden to the industry should be taken into account when changes are made. Totally replacing the current system requires a large re-education commitment on the part of every employee in the industry and government. The difficult, if not impossible to measure, cost of replacement, does not economically benefit the industry. Please refer to your own comments. Vice Chairman Federal Deposit Insurance Corporation on Regulatory Burden Relief Efforts before the Committee On Banking, Housing And Urban Affairs of the United States Senate, June 21, 2005 -- 10:00 AM 538 Dirksen Senate Office Building.

In conclusion, we feel enhancing the system would be better than replacing it.

Respectfully submitted,

David A. Jones

David A. Jones, Pres.
Grinnell State Bank
P.O. Box 744
Grinnell, IA 50112
641-236-3174 ph
641-236-4329 fx