From: Ruth Schaefer
Sent: Tuesday, February 10, 2004 10:05 AM
To: Comments
Subject: Proposed Comments - 12 CFR Part 345 - Community Reinvestment
Act Regulations
To Whom It May Concern:
I work for a bank ($87 million in assets) in a holding company that
owns 12
banks in three states (Minnesota, North Dakota and Wisconsin), with
asset
size ranging from $24 million to $232 million. I would like to lend
my
support to the current proposal, which redefines the definition of
a small
institution from $250 million to $500 million without any regard
to holding
company asset size. Currently, the holding company is nearing the
$1 billion
mark. In a few years with the current definition, the twelve 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.
Thank you,
Ruth Schaefer
Operations Officer/Compliance Officer
Valley Bank & Trust, New Ulm, MN
