On behalf of Bartow County Bank located in Cartersville, Georgia, I
would like to respond to the proposed changes to the Community
Reinvestment Act referenced in the FDIC release #PR-5-2004 dated January
20, 2004.
I believe that in the ever-changing banking environment of today,
faced with larger and larger bank mergers and acquisitions, that the
proposed increase in the asset size definition of small banks is both
timely and appropriate.
As more and more community banks quickly attain the current asset
size of $250,000,000.00 that is now used to determine large banks versus
small banks, I believe that the proposed asset size increase to
$500,000,000.00 is more practical for both record keeping purposes on
the bank level, as well as the monitoring and compilation of information
by the FDIC.
Thank you for allowing comments from those of us most directly
affected by proposed regulation changes.
