BankFirst Financial Services
From: Debbie Kirk [mailto:dkirk@bankfirstfs.com]
Sent: Monday, March 27, 2006 4:44 PM
To: Comments
Subject: Commercial Real Estate Lending (CRE)
The proposed Commercial Real Estate Lending (CRE) regulation would unfairly target community banks. This proposal would be extremely costly and burdensome to the community bank, and would leave our bank with no choice other than to drastically reduce our CRE lending.
We believe we already have good risk management practices in place to monitor CRE lending. Proposed guidance is unnecessary. Real estate standards and guidelines are already in place and are enforced by examiners with every exam.
All of our banks are located in counties recently affected by Hurricane Katrina. As a result of this disaster, over the next five to ten years, there will be the necessity for many rebuilding projects in these disaster areas. All of these projects will fall under the CRE regulation as proposed. Banks located in these areas designated as disaster counties certainly should be exempt from any new regulation concerning commercial real estate lending.
Jerry T. Wilson
CEO
BankFirst Financial Services
Macon, MS 39341
Contact: Regs@fdic.gov