Basel III Extension Letter

a letter dated August 2, 2012, IBAT President and
CEO Chris Williston has asked the heads of each of the federal agencies to
extend the comment period for ninety days for banks, trade groups and other
interested parties on the proposed Basel III capital plan and standardized
approach to risk weighting of bank assets. The comment period currently
ends on September 7, 2012.

is a very complex set of proposals," Williston said.  "The
industry just needs more time to carefully consider the ramifications specific
to their bank."

addition to asking for the comment period extension, IBAT encouraged the
agencies to develop a calculator that financial institutions could use to
determine their Tier 1 capital level, assuming the proposals are adopted as
currently written.

has been very vocal in meetings with the regulatory agencies in Washington
about the potential detrimental effects these proposals will have on community
banks, and encourages bankers to seriously analyze and respond with comment
letters of their own.  IBAT will distribute copies of its own comments for
member banks as soon as they are available.