FDIC Federal Register Citations

From: Donald Sherman
Sent: Monday, September 24, 2007 4:20 PM
To: Comments
Subject: Consolidated Reports of Condition and Income, 3064-0052

The requirement to separately report interest and fee income on 1-4 family residential loans will require a lot of changes in our general ledger and loan processing systems.  Since fee income is reported and included with interest, any all fees related to a 1-4 family loan will now have to be captured and reported separately from all other real estate loans.  This is possible, but it will involve a lot of changes not only to our computer systems, but also changes in processing by our loan personnel as well.  Monitoring of 1-4 family loans can still be performed by analysis of RC-C.  Thank you for your consideration.