FDIC Federal Register Citations

Bank of North Carolina

March 25, 2004

Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

RE: 12 CFR Part 345

Dear Mr. Feldman:

As the Compliance Officer for Bank of North Carolina based out of Thomasville, North Carolina, I appreciate the opportunity to comment with respect to the proposed amendments to the CRA regulations.

Increasing the asset threshold for what constitutes a "small institution" for CRA purposes to $500 million, or preferably $1 billion, would clearly be a positive step toward reducing regulatory burden without diminishing the purpose for which the Community Reinvestment Act was enacted in 1977. Since the CRA regulations were revised in 1995, small banks have become subject to significant new regulatory requirements while continuing to provide quality financial services to the communities we serve. Increasing the asset threshold for small institutions to $500 million would reduce the amount of total industry assets subject to the CRA test for large institutions by less than one percent. Raising the threshold to $1 billion would result in a reduction of only four percent. To increase the asset threshold to the higher amount would effectively address current circumstances as well as anticipated industry growth.

I appreciate the opportunity to comment regarding this important issue and urge the Agencies to adopt the recommended CRA amendments.

Michelle W. Ferguson
Assistant Vice President
Compliance Officer
Bank of North Carolina
831 Julian Ave
Thomasville, NC