First
State Bank
From: jlindsey@firststatebank.com [mailto:jlindsey@firststatebank.com]
Sent: Monday, April 19, 2004 6:11 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: REGULATORY BURDEN REDUCTION
Gentlemen:
I would offer the following comments on your request for ideas about
regulatory relief.
1. On each regulation it should determined if the consumer is truly
benefiting from the regulation. We know the banks are not receiving
any
benefit.
2. On each regulation it should be determined if the regulators can
explain
the regulation to the bankers - and all of the updated remarks.
3. The total consumer benefit should be compared to the total cost
of
compliance.
When the consumers do not understand the documents why should they
receive
the documents?
When different regulators can not agree on what the regulations
mean how can
the banks comply?
It is unrealistic to believe that anyone can protect everyone from
their
stupid mistakes. If the lender wants to mistreat or cheat the customer,
the
customer will probably be mistreated or cheated irregardless of the
regulation.
All lenders should have the same burden of compliance with consumer
regulations. Why should a small bank be subjected to a week long
examination when, proportionally, big banks do not have the same
burden.
Why do some lenders not have any compliance examinations.
Bankers do understand that regulators are trying to enforce congressional
mandates. Why don't the various regulators, as a group, explain these
facts
to congress?
My bank spends a tremendous amount of time, money and effort on
our
compliance programs. We receive high marks on our compliance exams.
Our
customers would not be treated any differently without most of these
regulations and would probably not be charged as much interest.
An entire industry has been built on compliance. We have separate
examiners
that are compliance specialists. We have compliance officers. Many
compliance advisors and auditors are doing well. We have software
vendors
that specialize in compliance programs. The consumers pay for these
industries in the long run.
Any regulatory relief would be welcomed.
Sincerely,
James D. Lindsey
COB, President & CEO
First State Bank, Mesquite, Texas
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