FDIC Federal Register Citations

Sevier County Bank

August 25, 2004

Mr. Bob Feldman
Executive Secretary's Office
550 17th St. NW
Washington, DC 20434

Re: Comment on CRA proposal

Dear Mr. Feldman:

As a small community bank, (Sevier County Bank, Sevierville, Tennessee) we support raising the CRA small institution threshold to $1 billion with a new community development criterion that would provide us with a choice among community-based lending, investment and service activities.

In our earlier comment letter, we expressed our concern regarding the unnecessary regulatory burden the $250 million limit will cause. During this phase in the growth of our bank, the cost of this detailed regulation at $250M is too high and hurts earnings considerably. This still rings very true.

Regulatory burden is hurting all community banks – ours and those across the nation. As community banks, we are the heart of our communities. We are the ones reinvesting in our communities in many ways, even though all those ways are not considered in an exam.

Once again, we support raising the CRA small institution threshold to $1 billion and adding a new community development criterion that would provide us with a choice among community-based lending, investment and service activities.

Thank you for listening to the comments you received on your first proposal request. Please consider our comments again.

Sincerely,
W.S. Brown