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  • Comment Detail

  • Date: 12/17/19
    First Name: Ken
    Last Name: Starks
    Organization: Allied First Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB05

  • Comment

    Well I am pro Deregulation in our industry, I do not fully agree with this proposed legislation. I DO believe that an adverse test could be removed and DO agree that the asset floor should be increased .... I believe that a floor of $250B is too high. Well the largest of institutions would still be included, Minnie significant institutions would be exempt. While I am not aware of the size of every proposed institution, I would believe that a lower threshold of perhaps 100B would be more appropriate. As a caterer originator and branch manager I am very familiar with secondary markets concerns and previous testing. As one who went through a previous meltdown and was directly impacted, I believe it is wise to still remain prudent while not causing smaller institution is a financial burden that this testing can incur. There are many other areas of Dodd Frank that I believe also need review and revision. Thank you for the opportunity to comment