From: Anderson, Monica M [mailto:MAnderson@hubank.com]
Sent: Thursday, August 11, 2005 10:38 AM
To: Comments
Subject: Annual Independent Audits and Reporting Requirements

I would like to comment on the proposed change to the Annual Independent Audits and Reporting Requirements of 12 CFR Part 363. I support the raising of the threshold from $500 Million to $1 Billion for internal control assessments by management and external auditors. If the threshold is raised a financial burden will be removed for several Community Banks. Community Banks with assets above $500 Million have a substantial financial costs associated with FDICIA compliance...this includes external auditors, additional test work and personnel. Community Banks will continue to evaluate the effectiveness of internal controls, document these results and report them to management and the Audit Committee. The raising of the threshold will not result is less effective internal controls.

It would be very helpful and beneficial if this ruling can be finalized in a timely manner. Several requirements of FDICIA are completed each quarter and it would be helpful and cost effective to know as timely as possible if this testing needs to be continued or not.

Thank you,

Monica M. Anderson
Senior Internal Auditor