Stonegate Bank
From: Seleski Dave
Sent: Thursday, January 26, 2006 11:02 AM
To: Comments
Cc: Cameron Steve ; Alex Sanchez; Jerry W. Oliver
Subject: Proposed guidance concerning Concentrations in Commercial Real Estate Lending
To whom it may concern:
I recently received a copy of the proposed guidance concerning Concentrations in Commercial Real Estate Lending. Needless to say, I was extremely alarmed by the various proposals. From an overall perspective I do not believe it is healthy for the various regulatory bodies to dictate policy in terms of how a Bank manages their overall operations as long as they are operating under the business plan originally proposed and approved by the regulatory bodies.
Specifically I oppose this guidance for several reasons:
1) Every Bank and every geographic reason is different. To arbitrarily set limits that encompass Banks with capital ranging from $7MM to billions is problematical at best and unfair. Each Bank should be evaluated on a case by case basis. The examiners should consider the overall capital structure of the Bank, historical losses, demographics of the market served, and the quality of the underwriting. Ultimately, it should be the Banks Management and Board in consultation with the various regulatory bodies that determine if there is undue risk.
2) The description of how a Bank does increased monitoring or due diligence if it is above the set limits is too subjective. It is very similar to BSA, which in my opinion is still not examined consistently from Bank to Bank or region to region.
3) The consumer will ultimately lose. If this guidance was to be passed, many of our customers would be forced to use a large regional Bank for their real estate lending needs. They are not set up or staffed to handle that volume. In addition, the consumer would suffer in terms of pricing (less competition- higher pricing).
4) Banks will be forced to lend money on what I view as less profitable assets and potentially riskier credits. Overall, I believe this guidance will make Banks less profitable and overall their loan portfolios will be weaker as a result.
Sincerely,
Dave Seleski
President/CEO
Stonegate Bank
Contact: Regs@fdic.gov