Public Comment CRE Lending Peoples Bank Lawrence KS

Kansas Wint Winter, Jr. Overland Park Peoples Bank Ottawa Chief Executive Officer Lawrence and General Counsel March 2, 2006 thLouisburg 4831 W. 6 St. Paola P.O. Box 1795 Lawrence, Kansas 66044 New Mexico (785) 842-4004 Taos Fax: (785) 842-5842 Albuquerque wwinter@bankingunusual.com Red River Re: Comment on Proposed Guidance: "Concentrations in Commercial Real Estate Lending" (Fed Docket No. OP-1248) Ladies & Gentlemen: The Board of Directors of Peoples Bank, Lawrence, Kansas appreciates the opportunity to comment on the proposed guidance entitled “Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices (Guidance)”. Our comments are as follows: We object to the proposed Guidance and urge the Agencies to reconsider the Guidance for the following reasons: A. The Guidance is Vague and Ambiguous and Subject to Inconsistent Application. B. Depending on Interpretation, Application of the “Suggestions” of the Guidance would be Burdensome and Oppressive. C. The Guidance Represents Poor Policy as it is Potentially Counter Productive to Sound Credit Quality. By way of background, Peoples Bank is a $320,000,000 community bank with operations in northeast Kansas and northern New Mexico. Our earning assets consist primarily of loans made within the communities in which we do business. A very large percentage of our loans are secured by commercial and residential real estate. As Commercial Real Estate (“CRE”) is ...