The chairman
of Twin City Bank is a successful real estate developer. His real estate
investment activity predates by many years his involvement with the bank.
He and his family members hold various real properties in many
different legal entities.
Because of
his status as an executive officer he must continually update and
present a listing of all credit facilities with FDIC insured
institutions. That list is substantial. Furthermore, it is disappointing
this institution cannot lend on any of his projects solely on the
grounds of his status as an executive officer. Such limitations should be
no different than those imposed on other board members subject to Reg O.
Please
consider revisions that might ease the reporting burden and enable more
flexibility for executive officers with outside, unrelated interests with
borrowing needs.
Thank you for
the opportunity to comment.
Gordon
Silaski
SVP and Chief
Lending Officer
Twin City
Bank
Little Rock,
Arkansas
