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FDIC Federal Register Citations From: ghoskins@fmbnc.com [mailto:ghoskins@fmbnc.com] To: Robert Feldman, Executive Secretary, FDIC We are very much in support of the proposed changes to Part 363 of the
FDIC's regulations. F&M Bank is a $460 million non-public commercial bank
that is approaching 100 years in operation as it was founded in 1909. There
are a number of reasons we believe the proposed changes make good business
sense and they are as follows: 1) we, like most financial institutions under
$1 billion, are not complex in operation. I think you will find most
institutions in this asset size conduct plain vanilla branch banking, taking
in local deposits from the community and lending it back out; therefore
maintaining low inherent risk, 2) whether reviewed by an outside entity or
not, we continue to strive toward strong internal controls as they are in
our best interest, and 3) multiple reviews already exist (including an
annual independent audit of our financial statements which internal controls
testing is within this scope, ongoing internal audits, and annual exams from
state and/or federal regulators). In fact, although we are not public, our
most recent external audit had applications from the Sarbanes Oxley Act. Thank you for your time and attention to this subject. There is satisfaction in knowing the FDIC is applying timely and reasonable cost vs. benefit analysis in the review of this matter. F&M Bank phone 704.633.1772
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Last Updated 08/23/2005 | Regs@fdic.gov |