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FDIC Federal Register Citations


M C BANK & TRUST CO.

From: Mike Bourgeois
Sent: Tuesday, August 24, 2004 9:42 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I am a vice president of an $182,000,000. bank and I agree to extending the small bank rule up to a $500 million bank. I do not believe in extending it up to $1 billion.

I believe banks in excess of $500 million have an advantage over the smaller community banks. The $500 million mark is a good dividing line between the small bank and the large bank. I feel a bank in excess of $500 million in size is forced to have the sophistication and expertise needed to handle day to day operations as well as for CRA requirements for large banks. Small banks would be more heavily burden because they may lack the sophistication and expertise. They would have to spend too much of there bottom line resources toward CRA guidelines for large banks.

 

 

Last Updated 08/24/2004 regs@fdic.gov

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