FDIC Federal Register Citations

via e-mail

CITIZENS BANK OF BLOUNT COUNTY

March 9, 2004

Dear Sir or Madam:

As a community banker, I strongly endorse the federal bank regulators’ proposal to increase the asset size of bank eligible for the small bank streamlined Community Reinvestment Act (CRA) examination from $250 million to $500 million and elimination of the holding company size limit. This proposal will greatly reduce regulatory burden. I am the President and CEO of Citizens Bank of Blount County, a $242 million asset bank located in Maryville, Tennessee.

With all the mergers and conglomerate banks, the definition of small bank has certainly changed. With this change, the definition of a small bank as defined in the CRA examination process should also be modified. Community banks find it difficult enough competing with $500 billion banks surrounding them. When regulators lump our banks with these huge institutions, it restricts us from doing the very thing CRA was intended for, and that is to serve our communities. Raising the CRA small bank ceiling will support the survival of community banks. Survival of the community bank will strengthen the communities we serve.

In summary, I believe that increasing the asset-size of banks eligible for the small bank streamlined CRA examination process is an important first step to reducing regulatory burden. I would further urge agencies to seriously consider raising this asset-size to at least $1 billion to better reflect the current demographics of the banking industry.

Sincerely,

Joe Bruce
President & Chief Executive Officer
Citizens Bank of Blount County
Maryville, TN