To: FDIC
From: Dawn L. Simon, Compliance
Valley Bank Dundas
Frandsen Financial Corporation
Dundas, MN 55019
Date: 2/11/04
Re: Proposed Comments - 12 CFR Part 345 - Community Reinvestment Act Regulations
I work for a bank holding 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 ($1 billion holding
company) to $500 million. Currently, the holding company is nearly 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.
Also, it would be very hard to get a Low Satisfactory rating on the Investment
Test.
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