FDIC Federal Register Citations

The First State Bank of Burlingame


From: Steve DeWitt
Sent: Monday, March 15, 2004 5:26 PM
To: Comments
Subject: Jan. 27, 2004 - Notice of regulatory review

Thank you for giving us the opportunity to comment on this most important
issue.

We are in favor of any regulatory burden relief for a bank with assets of
$150 million or less.

One regulation in particular that needs consideration is the Home Mortage
Disclosure Act (HMDA). Being a new reporter effective this year, we feel
HMDA should have a small-bank rule similar to CRA or a much higher asset
exemption above the current $33 million level. Another example of a basis
for exemption when rural counties are included in an MSA would be to look at
the percentage of a bank's loan portfolio made to the primary MSA county and
establish a floor limit for reporting based on that percentage.

Another part of HMDA which appears to be outside of the intent of the rule
is the definition for refinancing. It doesn't seem to make much sense to
report the refinancing of a commercial or agriculture loan that is only
partially secured by a dwelling.

Please consider these comments during the evaluation process. We feel they
make a lot of sense for a small rural bank such as ours.

Sincerely,

Steven DeWitt
Sr. Vice President and Cashier
The First State Bank of Burlingame
Burlingame, Kansas