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January 13, 2006 Public Information Room Robert E. Feldman, Executive Office of the Comptroller of the Secretary Currency Federal Deposit Insurance Corporation th250 E Street, SW 550 17 Street, NW Mailstop 1-5 Washington, DC 20429 Washington, DC 20219 Attention: Comments/Legal ESS November 9, 2005 Attention: Docket 05-16 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. 2005-40 Docket No. R-1238 Re: Risk-Based Capital Guidelines; Capital Adequacy Guideline; Capital Maintenance: Domestic Capital Modifications 1 Dear Sir or Madam: The Independent Community Bankers of America (ICBA)appreciates the opportunity to offer comments on the Advanced Notice of 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 members, representing more than 17,000 locations nationwide and ...
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