Federal Deposit
Insurance Corporation

October 8, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Re: RIN Number 3064-AC50

Gentlemen:

I have been involved with small-town country banks for the past 43 years. My current title is President of the holding companies that own the banks where I’m involved, which consists of seven bank charters with six branches. The size of our banks range from total assets of $12 million to $120 million.

I firmly support the FDIC’s proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion, regardless of the size of the bank’s holding company. I truly believe the resources spent complying with the Act, which we believe in our case represents between 16% and 20% of the salary structure, is unreasonable and unnecessary.

The FDIC, at least in our territory, is staffed with highly capable examiners, so if a bank was not fulfilling their community chores, especially banks the size we’re referring to, the examiners could report common sense non-compliance to their supervisors who should be in a position to review with management their concerns and in turn receive cooperation by the offending bank.

In my 43 years in the country, I’ve never seen a situation with the local banker wasn’t doing everything he could to help make the town thrive by furnishing adequate credit, and in most cases there’s so many banks in these rural communities now, if a bank was not furnishing adequate credit, they would be “squeezed out” by the bank next door.
My opinion is the FDIC’s proposal will help to strengthen the banking system without damage to anyone.

Respectfully,

L. A. Amundson, Chairman