| February 14, 2006
Office of the Comptroller of the
250 E Street, SW
Public Information Room
Mail Stop 1-5
Washington, DC 20219
Attn.: Docket No. 05-21
|
Regulation Comments
Chief Counsel’s Office
Office of Thrift Supervision
1700 G Street, NW
Washington, DC 20552
Attn.: Docket No. 2005-56
|
Robert E. Feldman
Executive Secretary
Attn: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
|
Jennifer Johnson
Secretary
Board of Governors of the
Federal Reserve System
20th St. and Constitution Ave, NW
Washington, DC 20551
Attn.: Docket No. OP-1246 |
Re: Proposed Guidance- Concentrations in Commercial Real Estate Lending,
Sound
Risk Management Practices
71 FR 2302 (January 13, 2006)
Dear Sir or Madam:
America’s Community Bankers (ACB) appreciates the opportunity to comment on the
Proposed Guidance –Concentrations in Commercial Real Estate Lending, Sound Risk
Management Practices (“Proposed Guidance”) issued by the Office of the
Comptroller of the Currency, the Board of Governors of the Federal Reserve
System, the Federal Deposit Insurance Corporation, and the Office of Thrift
Supervision (collectively, the “Agencies”).
ACB urges the Agencies to extend the March 14, 2006 due date for comments on the
Proposed Guidance by 30 days. The Proposed Guidance was published in the Federal
Register on January 13, 2006 and we believe an extension would be beneficial for
all parties.
The proposal is extremely complex and has far-reaching consequences for our
members, as well as for the nation’s mortgage markets. We believe that it will
take an additional 30 days to complete the necessary evaluation and collect
comments and data from our membership. A 30-day extension would enable our
association to provide the Agencies with the most meaningful comments on the
Proposed Guidance.
For these reasons, we request that the Agencies extend the comment period on the
Proposed Guidance to April 13, 2006. We appreciate your consideration of the
requested extension and urge you to make a determination as quickly as possible.
Sincerely,
Patricia A. Milon
Senior Vice President
Regulatory Affairs
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