FDIC Federal Register Citations

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From: Julie Carnahan

Sent: Tuesday, August 05, 2003 8:46 AM

To: regs.comments@federalreserve.gov; Comments;

regs.comments@occ.treas.gov; regs.comments@ots.treas.gov

Subject: EGRPRA

We are a rural 40 million bank in Saunders County, Nebraska, with a 104 year

old charter and over 100 years experience in our loan officers. The

regulation that requires us to obtain an outside/certified appraisal on

loans of $250,000 and more is out of date and a burden. The $250,000

threshold has been the same since the regulation was put on the books many

years ago with no allowance for inflation. It requires us to spend $1000 to

$1500 on a farm appraisal to tell us less than what we knew about the value

of the land at the time the loan application was received.

John C. Barry

Oak Creek Valley Bank

PO Box 8

Valparaiso, NE 68065