BankCEO
Jul 23 2008, 10:18 PM EDT
The accounting rules and regulatory guidance sure leave a lot to be desired. They want an allowance that fully provides for all losses, but losses that have already occurred have already been written off. So now we do calculations based on past experience, rate or grade loans as if they were term papers, and come up with a number. There doesn't seem to be an room for an estimate to accommodate estimation errors. Two years ago, regulatory agencies were telling us our allowance was too high. Now they want us to add to it.

How are you dealing with these issues? What are you seeing from examiners? Have you been able to maintain the allowance at a reasonable level?