Federal Deposit
Insurance Corporation

NexBank Capital

From: Mike Rossi
Sent: Thursday, November 15, 2007 6:08 PM
To: Comments
Subject: Part 363-Independent Audits and Reporting Requirements

The proposed revisions to this rule are entirely too burdensome on banks who are under $1BB of total assets. 

Our institution, at $450MM, currently spends over $500,000 annually on compliance.  If we make a few loans, we will hit $500MM.  We simply cannot afford the additional expense associated with 363 compliance.

Please do not implement 363 for financial institutions under $1 Billion in assets.

Mike Rossi, Senior Vice President, Chief Financial Officer
NexBank Capital, Inc.
13455 Noel Road, Suite 2220, Dallas, TX 75240