Federal Deposit
Insurance Corporation

Comments@FDIC.gov

October 20, 2004

Re: RIN No. 3064-AC50 Proposed Increase in the Threshold for the Small Bank CRA Streamlined Examination

Dear Sir or Madam:

I am writing to voice our bank’s support for the federal bank regulatory agencies’ (Agencies) proposal to enlarge the number of banks and savings associations that will be examined under the small institution Community Reinvestment Act (CRA) examination. The agencies propose to increase the asset threshold from $250 million to $500 million and to eliminate any consideration of whether the small institution is owned by a holding company. This would be a very good change and is clearly a major step towards an appropriate implementation of the Community Reinvestment Act and should greatly reduce regulatory burden on those institutions newly made eligible for the small institution examination, and I strongly support both of them. An increase to $1 billion may be more appropriate.

We certainly don’t mind doing our part to help protect customers and the country from illegal and unfair activities. However, the more regulations we have to keep up with, the more manpower we have to employ for compliance, the harder it is for us to serve our community and earn a reasonable profit. Our proposal would be to raise the asset threshold for the small institution examination to $1 billion. This would be appropriate for the following two reasons.

First, keeping the focus of small institutions on lending, which the small institution examination does, would be entirely consistent with the purpose of the Community Reinvestment Act.

Second, raising the limit to $1 billion would have only a small effect on the amount of total industry assets covered under the more comprehensive large bank test.

Consider our bank, First National Bank of South Georgia, which is roughly a $75 million bank that is owned by ABC Bancorp out of Moultrie, Ga. that recently exceeded the $1 billion threshold. First, our bank has to spend much more time coding loans and filling out paperwork than ever before. This takes away from the bank’s ability to be profitable and serve its customers. Then, the holding company has to delegate numerous employees towards this regulation just to try and ensure we are in compliance. We have definitely seen an increase in regulatory requirements over the years with some being good and some being bad. Please help us out with some red tape and allow us to continue to serve our customers in an efficient friendly manner with the best service possible.

Thanks for your time and consideration of our ideas and suggestions. If we can ever be of service or if you have any questions, please feel free to contact me at 229-434-4527 or by e-mail at charles.owens@abcbancorp.com

Sincerely,
Charles P. Owens
Senior Vice-President
First National Bank of South Georgia