------Original Message------
When I read these articles, I am always surprised at the "one size fits all" attitude. I examined banks as an FDIC examiner for eight years before I began my career as a banker and our approach was always risk based. To institute a broad based rule of 25 percent capital minimum is to penalize the well run community banks and restrict their operations. I know from experience that most community banks have loan portfolios full of long standing customers with good payment histories and loans secured by real estate valued conservatively. Small banks have the luxury of knowing all their customers on a first name basis and we use that firsthand knowledge to recognize loan issues early and reserve for them appropriately. So in economic downturns, we hold a higher capital account through the ALLL. Main street community banks did not contribute to the 2008 recession; however, we did suffer from the fallout of the Dodd Frank act. My hope is that the decisions makers take into consideration that not all banks are alike and "one size does not fit all".
Jolene A Muscha
President
Bank of Glen Ullin
Glen Ullin, ND 58631
701-348-3613
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