FDIC Federal Register Citations

American State Bank

From: David Dudley
Sent: Monday, August 23, 2004 12:06 PM
To: Comments
Subject: RIN number 3064-XXXX

We are in agreement with the new proposed definition of a small bank to be $1 billion of either of the prior 2 calendar quarters. This would allow us to spend the time meeting the needs of our community versus the extra amount of time for the data collection and reporting requirements. We spend an enormous amount of time collecting data for HMDA and other activities which limits the time to help our customers. Smaller banks are at a disadvantage when competing with larger banks that have bigger budgets. Large and small banks must all adhere to the same rules which puts a burden on small banks. We have found in compliance exams and other regulatory exams that the large bank exams do not appear to be examined as closely. As a result, it appears that the regulatory agencies spend more time reviewing and examining small banks. Large banks have approximately 89% of total assets nationwide, but smaller banks by number of institutions have 94% under $1 billion.

We will continue to do all we can to meet the credit needs of low to moderate income borrowers. We are in rural communities as well. Community developments activities and investments are difficult to obtain.

Hopefully a decision will be made very quickly since some institutions will be required to purchased data collection software and change loan administration procedures that will be costly effective 1-1-2005.

Thank you for your consideration.

David Dudley
EVP
American State Bank
POB 3080
Jonesboro, AR