Comment on FR Doc # E8-29151

These comments are in regard to the new federal regulations covering B&I loans and more specifically the written summary of loan origination and servcing policies and procedures. I believe that this whole process is, once again, the federal government coming up with procedures and protocols without talking to the lenders and gaining their input. First of all this process is redundant as the questions that are being asked are already covered by the FDIC and or the Comtroller of the Currency. Every bank has to have their credit procedures (loan making, collections, write offs, terminations, etc.) approved by the Feds. So to submit that information to the USDA is reduncancy in action. Why not have these additional requirements be inflicted upon organizations that do not have to already jump through government hoops. Second the USDA is asking to obtain inforamtion that in many ways is proprietary to the institution being asked. Everyone knows that the government can't keep a secret! It seems to me that the USDA program wants to be as stream lined as possible to incent more lending institutions to avail themselves of your very valuable service. There is out there already a general consensus that the program is complex and not user friendly. To implement your proposed suggestions would be to add fuel to the proverbial fire. How about this for a laugh the governement people in charge of altering or adding new regulations actually speak to the lenders that are presently using the system. We know what is working and what can be improved upon! Instead of that you devise these regulations in a vacuum, devoid of lender input! How does that make any sense at all? You guys in Washington are so fearful of meeting with lenders ,for fear that you will be tainted with the common sense virus, that you go out of your way to leave us out of the process!! Understand that the lenders involved in the program believe in it and are your biggest advocates! We are not the enemy or even the obstruction. Let us actually work together to form a union of people seeking a common goal! If we approach this as a TEAM concept (Together Everybody Achieves More) we will come up with a system that will truly be beneficial to all parties concerned. I hope that this is actually read, but I doubt it will be.