I am the President of a $58 million rural bank in Wisconsin. The bank is owned by a multi-bank holding company with total holdings of between $900 million and $1 billion. I am writing in favor of the proposed changes to 12 CFR Part 345, which would change the definition of a small institution from $250 million to $500 million, and would eliminate the inclusion of banks owned by holding companies over $1 billion in size. It appears that our holding company will be at the $1 billion mark in the next year of two, and that would cause us to incur significant costs in order to stay in line with the current regulation. As we are a rural bank, and invest heavily in our community already, we don't need to be burdened with more testing and documentation to prove what we are already doing.

Charvey Spencer
President
Rural American Bank Luck
206 Main Street South
Luck WI 54853