I would like to lend my support to the current proposal, which redefines
the definition of a small institution from $250 million ($1 billion holding
company) to $500 million. Currently, our holding company, Frandsen Financial
Corporation, is near the $1 billion mark, and our own institution, near the
$250 million mark. Reporting under the large institution definition would
result in a very significant increase in compliance burden in order to meet
the new reporting requirements. In a few years, with the current
definition, our twelve holding company banks will incur significant
regulatory burden under the large institution definition. Many of the banks
would have to add staff with the increased recordkeeping requirements. Also,
it would be very hard to get a Low Satisfactory rating on the Investment
Test.
Please continue to support the current proposal.

Kim Anderson
Vice President - Retail Banking Manager
Community Bank of the Red River Valley
Grand Forks, ND 58201