FDIC Federal Register Citations

Northwestern Bank


March 9, 2004

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

Dear Sir or Madam:

As Community Bankers, we strongly endorse the Federal Bank regulators proposal to increase the asset size of banks 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 the regulatory burden for our bank. Our bank is Northwestern Bank of Chippewa Falls, Wisconsin with asset size of $270 million dollars.

The small bank CRA examination process has worked well at our bank. We are just starting (as of 1/1/04) to use the large bank criteria in reporting. We have observed that many of these items do not apply to our bank, but are costly and time consuming to collect. We feel that the costs far outweigh the benefits of this program. Community activists do not seem to care about costs and the burdens that these regulations impose on small banks.

We believe that the small banks are the backbone of the community, and that these regulations reduce our effectiveness in helping out our community.

Regulatory burden must be reduced for community banks to prosper. Increasing the CRA exemption to $500 million will be a first step toward that goal.

Northwestern Bank, Chippewa Falls, WI