Federal Deposit
Insurance Corporation

First National Bank

From: Paul Welle [mailto:pwelle@fnbbemidji.com]
Sent: Wednesday, October 20, 2004 4:10 PM
To: Comments
Cc: psmith@aba.com
Subject: RIN No. 3064-AC50

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: FDIC Proposed increase in the Threshold for the Small Bank Streamlined Examination

Dear Sir or Madam:

I am Vice-President of First National Bank Bemidji. Bemidji is a small town of 12,000 people located in northcental Minnesota. We have the largest Indian Reservation in Minnesota located just to our north. I am writing to support the FDIC’s proposal to raise the threshold of the streamlined small bank CRA examination to $1 billion without regard to the size of the holding company. Our bank is $360,000,000 in size. When we were under $250,000,000 and allowed

To be examined as a small bank we almost always received an Outstanding CRA rating. We have not changed any of our policies or backed off of our commitment to the community (including the Red Lake Indian Reservation). However, we are spending 100 times the amount of time trying to document where each one of our home loans is located on the federal BNA code as we had to do under the small bank guidelines. We are continuig to provide financing for Indian owned businesses as well as tribally run programs and businesses. Because our staff spend so much time documenting statistics which have no meaning (the BNA codes are arbitrarily drawn and do not define any low income areas in our county, Red Lake Reservation is the only low income area and it is a separate zip code so we can track it under the small bank guidelines) our staff become disgruntled and resent the CRA program. We support the concept and the spirit of CRA’s intent. For the past sixty years we have focused on being a true community bank. We also fail to meet the investment test because we cannot find mortgage backed securities within our lending area. I have not been able to find an investment company which can provide us with those low to moderate income mortgages which meet the test.

Please let the small community banks focus on what we do best, take care of our local customers and not have to spend an inordinate amount of time chasing after meaningless information.

Sincerely yours,

Paul Welle

First National Bank

Bemidji, MN