Comment Text:
This comment is also intended for the FDIC (our primary federal regulator).
Ranked by total dollars lent to agricultural, Stockman Bank of Montana is the 20th largest agricultural lending bank in the United States. We are very concerned that unintended consequences arising from an overally complex Volker regulation will decrease liquidity in the commodity futures market and therefore hurt the efficiency of those markets and make risk management more expensive and risky for our bank and our customers.
Writing a complex and detailed regulation intended to govern any anticipated outcome in this complex market appears to be an exercise in futility. Rather, we would encourage a regulation that incorporated broad regulatory principals, enforced by a trained regulatory work-force. That approach will combine regulation with the flexibility to address changing market conditions, market strategies and products.
