FDIC Federal Register Citations

Gwinnett Banking Company

September 29, 2004

Mr. Robert E. Feldman
Executive Secretary
A ttention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429 I

Re: RIN Number 3064-XXXX

Dear Mr. Feldman:

As a career bank officer employed by Gwinnett Banking Company (GBC), a $283 million community bank headquartered in Lawrenceville, Georgia, I appreciate having the opportunity to respond to the recent FDIC request for additional comments on the proposed) changes in the "Small-Bank" CRA Reporting Threshold. Although I can only speak directly for myself and about my bank, I believe my comments will have applicability to many, if not most, of the community banks spread across America.

I don't know if the following factors make GBC especially unique in any way, but they do apply to the core values of our company.: We' operate our bank out of two locations, employing a staff of approximately-45. What I believe to be most distinctive about GBC is the make up of our staff. Most of us" have-been in banking for over 25 years and many of us have worked closely together during those 25 years. As a group, we are experienced, seasoned and good at what we do; we share many common values and together form a close knit "work family". You may now be asking yourself "what does this! have to do with CRA."? We believe these shared values have a significant influence upon our bank's collective awareness of and commitment to the needs of our community as well as our obligations and responsibilities as a good "corporate" citizen within our community. . ,

However, as a group, we, the people of GBC, do not consider ourselves to be "just" a singular "corporate" citizen, rather we see ourselves as a group of individuals privileged to be able to join together to work and live within our community. To a person, our directors and employees feel a closeness with and a strong commitment to support our community, just as our community supports us. We do not consider our community involvement to be an "obligation"; rather we view it as a positive opportunity to further enrich our community in ways beyond simply "writing a check".

The following list is but a sampling of GBC's community involvement during its seven years of operations: .

1 Annually, in concert with the. Holiday Season, GBC and its employees provide "Christmas" for needy families as well as volunteering time and financial resources to the Salvation Army and Toys for,Tots. among other worthy charitable organizations.

2. Individual employees regularly participate in school based "Adopt-a-Child"`programs:

3. In 2003, GBC donated over $50,000 in cash and the GBC directors, employees, friends and selected customers donated 100% of the labor and expertise necessary to build a "Habitat-for-Humanity" home within our community for a single mother and her daughter.

4. Earlier this year, employees, friends and customers of GBC participated in the "Relay for Life," walking together to raise over $11,000 to help fight breast cancer.

5. GBC has been a long-term sponsor, financial and otherwise, of Hi-Hope, a local support organization that provides employment programs and day-care facilities to adults and children with developmental disabilities.

6. GBC has financially supported many community sponsored recreational athletic leagues for children between the ages of 4 to 18.

7. GBC sponsors and supports many local schools through involvement in booster clubs for academics, community service and athletics.

8. GBC has locally maintained a direct partnership relationship with Benefield Elementary School.

9. GBC's Small Business Administration Lending Department works diligently to seek out and assist promising small business entrepreneurs sharing the dream of establishing a financially stable business of their own.

10. As of August 30, 2004, GBC qualified as the largest SBA lender operating in Georgia.

Although the above list could easily become quite lengthy, that should not be necessary as the list is nothing more than a small peek into the "heart and soul" of GBC and its directors and employees. We support our community because we want to, not because we have to. This commitment to our community will neither change nor be diminished in any way even if, "on paper," the CRA requirements regarding our community involvement are revised. GBC, although not a "small" bank, is certainly not a "large" bank. If CRA requirements remain as they are, GBC will attain the "large" bank classification effective December 31, 2004 and, in so doing, will immediately begin to implement the enhanced procedures necessary to insure that we continue to fulfill our community obligations as a "large" bank. The direct cost to be required of GBC to successfully meet those obligations is not fully known at this time, but we expect them to have a noticeable financial impact on the bank. Rather than having a portion of those dollars become absorbed into our overall cost structure, we would rather direct all of them outside the bank as "community funds" which we believe will be a higher and better use for those special and valuable financial resources.

In summary, we highly and strongly recommend that the FDIC raise the small institution CRA threshold from $250 million to the proposed $500 million or $1 billion level. In so recommending, we also understand that there will be expanded CRA requirements of the community banks in the "new" $250 million and above "small" bank range.

Sincerely,
Larry D. Key
Chairman, President and CEO