the harvard state bank - Federal Reserve Bank [PDF]

Oct 9, 2012 - HARVARD, IL 60033. TEL: 815.943. ... My name is Roger L. Lehmann, President/CEO of The Harvard State Bank,

0 downloads 4 Views 299KB Size

Recommend Stories


Untitled - Federal Reserve Bank
Don't ruin a good today by thinking about a bad yesterday. Let it go. Anonymous

Untitled - Federal Reserve Bank
Love only grows by sharing. You can only have more for yourself by giving it away to others. Brian

FEDERAL RESERVE BANK OF SAN FRANCISCO
Every block of stone has a statue inside it and it is the task of the sculptor to discover it. Mich

Untitled - Federal Reserve Bank of Minneapolis
At the end of your life, you will never regret not having passed one more test, not winning one more

Daniels v. Federal Reserve Bank of Chicago
Ask yourself: If you have one year left to live, what would you do? Next

GAO-12-18 Federal Reserve Bank Governance
Every block of stone has a statue inside it and it is the task of the sculptor to discover it. Mich

Daniels v. Federal Reserve Bank of Chicago
Ask yourself: Have I done anything lately worth remembering? Next

South African Reserve Bank
Life isn't about getting and having, it's about giving and being. Kevin Kruse

SOUTH AFRICAN RESERVE BANK Applic
Life isn't about getting and having, it's about giving and being. Kevin Kruse

Untitled - Reserve Bank of India
Life is not meant to be easy, my child; but take courage: it can be delightful. George Bernard Shaw

Idea Transcript


THE HARVARD STATE B A N K

THE HARVARD STATE BANK

35 N . AYER STREET HARVARD, IL 60033 TEL: 815.943.4400 FAX: 815.943.4759

HEBRON COMMUNITY FINANCIAL CENTER

COMMUNITY BANK OF ROCKFORD

COMMUNITY BANK OF OREGON

9605 MAIN STREET HEBRON, IL 60034 TEL: 815.648,2481 FAX: 815.648.4644

2470 EASTROCK DRIVE ROCKFORD, 1L 61108 TEL: 815.397.3111 FAX:815-397.3217

101 S. 4 T H STREET OREGON, [L 61061 TEL: 815.732.3111 FAX: 815.732.3115

September 2 8 , 2012

Jennifer J . J o h n s o n , Secretary Board of G o v e r n o r s of the Federal Reserve System 20th S t r e e t and Constitution A v e n u e , NW W a s h i n g t o n , DC 20551 Dear M s . Johnson: My name is Roger L . L e h m a n n , P r e s i d e n t / C E O of The Harvard H a r v a r d , I l l i n o i s . Our primary r e g u l a t o r is the F D I C .

State

Bank,

I am w r i t i n g to you today to express my concern relative to the capital regulation that is going to be put in effect as of January 1, 2 0 1 3 . In m y o p i n i o n , the Basel III if indeed covers the small c o m m u n i t y banks will g r e a t l y adversely affect them and their ability to m a k e loans to their c u s t o m e r s . I believe one example of this is that for m a n y years the r e g u l a t o r s have encouraged banks to m i n i m i z e their interest rate risk by having three and five year balloons N o w , with Basel III, this will a d v e r s e l y affect our risk rated c a p i t a l . Our Bank has about $240 million in assets of which a p p r o x i m a t e l y $150 million are loans to small businesses with our largest c o n c e n t r a t i o n being our one to four families which c o n s t i t u t e s about 30% of our lending p o r t f o l i o . In addition to this we m a k e , as I s a i d , loans to small businessmen and farmers in our geographic area. W h a t I have been able to d e t e r m i n e so f a r , in looking at the Basel III r e g u l a t i o n s is that if this covers banks such as o u r s , we will have to stop m a k i n g loans to small businessmen and real estate loans for our capital account under risk based capital will not support it and I assume that this will happen for m o s t of the c o m m u n i t y banks in the United S t a t e s . So t h e r e f o r e , we will end up with 25 large mega-banks in the c o u n t r y as the European model is at this t i m e . This is a real concern of m i n e for who will take care of the small businessmen and the consumers. It is m y understanding that when Basel came out 10 to 15 y e a r s ago, it was for the purpose of standardizing the accounting system for international banks and if a bank in Switzerland was going to make a trade or a contract with a bank in T o k y o , they needed to know w h a t their financial statements stood f o r . In the United S t a t e s , we've had

visit us o n l i n e at w w w . w e b h s b . c o m

Jennifer J. Johnson, Secretary

2

September 28, 2012

FASB regulations for standardizing our financial statements for many y e a r s . So, therefore, if a bank had a contract with another bank in a distant state, the two persons entering the contract could review these financial statements and understand the risks they are taking by entering into these contracts. I do believe there is a place for Basel international banks that do trade across countries. But, I do also believe that we community banks with the FASB accounting that years in the United States.

III in the world for the the globe into different do not need Basel III for has been in place for many

T h e r e f o r e , I request that you reconsider your proposal and limit this to the $10 billion and larger banks as originally planned. Thank you for giving me the opportunity to comment on the proposed new regulation and express my concern that this will be a detriment for the community banks and will have unintended consequences. I look forward to having dialogue with you on this subject. My telephone number is 8 1 5 / 9 4 3 - 4 4 0 0 . My E-mail address is [email protected]. Thank you from y o u .

RLL/kms

for your

time and c o n s i d e r a t i o n .

I look forward to hearing

Smile Life

When life gives you a hundred reasons to cry, show life that you have a thousand reasons to smile

Get in touch

© Copyright 2015 - 2024 PDFFOX.COM - All rights reserved.