As the CEO of MidCarolina Bank I am writing to respond to this
proposed rule. Once again the small community bank is painted with the
same brush that regulators often use when they rush to fix a problem.
This proposed rule will add increased cost to this and many other small
financial institutions with little regard to how it can be effectively
implemented. I urge you to carefully examine the process that is
undertaken to solve this challenge. I look forward to your progress in
helping smaller entities not bear the same brunt that the larger
institutions can absorb much more easily.