Public Comment AC96 Risk Based Capital Guidelines Independent Community Bankers of America

March 26, 2007 Office of the Comptroller of the Robert E. Feldman, Executive Currency Secretary 250 E Street, SW Federal Deposit Insurance Corporation thMailstop 1-5 550 17 Street, NW Washington, DC 20219 Washington, DC 20429 November 9, 2005 Attention: Comments/Legal ESS Attention: Docket 06-15 Jennifer J. Johnson, Secretary Regulation Comments Board of Governors of the Chief Counsel’s Office Federal Reserve System Office of Thrift Supervision th20 Street an Constitution Avenue, 1700 G Street, NW NW Washington, DC 20552 Washington, DC 20551 Attn: No. 2006-49 Docket No. R-1238 Re: Risk-Based Capital Guidelines; Capital Adequacy Guidelines; Capital Maintenance: Domestic Capital Modifications Dear Sir or Madam: 1The Independent Community Bankers of America (ICBA) appreciates the opportunity to offer comments on the Notice of Public Rulemaking (Basel IA NPR) issued by the banking agencies and published in the Federal Register on 1 1The Independent Community Bankers of America represents the largest constituency of community banks of all sizes and charter types in the nation, and is dedicated exclusively to representing the interests of the community banking industry. ICBA aggregates the power of its members to provide a voice for community banking interests in Washington, resources to enhance community bank education and marketability, and profitability options to help community banks compete in an ever-changing marketplace. With nearly 5,000 ...