FDIC Federal Register Citations

Bartow County Bank

April 5, 2004

FDIC
Legal
550 17th St. NW
Washington DC 20429

In RE: FDIC release #PR-5-004, dated January 20, 2004.
Changes to the Community Reinvestment Act.

Gentlemen:

On behalf of Bartow County Bank located in Cartersville, Georgia, I would like to respond to the aforementioned proposed changes to the Community Reinvestment Act.

In today’s rapidly changing banking environment, the proposed increase in asset size definition of “small banks” from $250,000,000.00 to $500,000,000.00 is both timely and appropriate.

Faced with mergers and acquisitions larger than ever, many community banks quickly attain an asset size of $250,000,000.00.The proposed increase to $500,000,000.00 is much more realistic. Record keeping, monitoring, and compilation will be much more practical at the bank level, as well as for the FDIC, under the proposed increase.

Additionally, the final paragraph of the above referenced release suggests that the CRA disclosure statement should contain the number and amount of small business and farm loans by census tract. I would appreciate clarification on exactly what monitoring information will continue to be required on these loans by banks that are classified as “small” under the proposed small bank classification of $500,000,000.00.

Thank you in advance for your consideration, and for allowing comments from those most affected by the proposed changes.

Sincerely,

Bartow County Bank
By: _________________________
Jacqueline M. Croft/ Bank Officer