FDIC Federal Register Citations

Citizens State Bank of Waterville

February 9, 2004

To Whom It May Concern:

I work for a bank ($24 million in assets) in a holding company that owns 12 banks in three states (Minnesota, North Dakota and Wisconsin), with asset size ranging from $24 million to $232 million. I would like to lend my support to the current proposal, which redefines the definition of a small institution from $250 million to $500 million without any regard to holding company asset size. Currently, the holding company is nearing the $1 billion mark. In a few years with the current definition, the twelve banks will incur significant regulatory burden under the large institution definition. Many of the banks would have to add staff with the increased record keeping requirements.

Thank you,
Paul Dornfeld
Vice President
Citizens State Bank of Waterville
Waterville, MN