FDIC Federal Register Citations

September 16, 2004

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

RE: Community Reinvestment, RIN number 3064-AC50; Proposal to Expand Eligibility for the Streamlined CRA Exam

Dear Mr. Feldman:

I am writing as CEO of a $135,000,000 community bank in northeast Mississippi. Our main office is in Baldwyn, a town of 3,500. We have three other branches in our county. My board and staff strongly support the FDIC proposals to increase the asset size of bank eligibility for the streamlined small-bank CRA examination.

Community banks are indeed different from larger institutions and should be judged accordingly. We recognize that if we do not reinvest in ALL of our area community that we serve, our community will die, and our bank will die! There are no outside areas where we can draw deposits from, nor are there any we are willing to make deposits to. Our customers, therefore, must include all income levels; and we have to be responsive to the needs of our community because there is no one else willing to offer this support.

It is a matter of good common sense that the less time community banks spend documenting and justifying what they do, the more resources they will have to serve ALL the people of their community. These improvements will encompass all income levels and aid in the development of towns, schools, and private development. The definition of "community development" to better serve rural communities would then very clearly define "What community banks DO". Our bank currently serves as depository for town, counties, school systems, and other governmental agencies. We work especially hard to develop our rural community and all the people in our trade area.

Our staff appreciates the FDIC's proposed changes to CRA and all efforts to reduce or eliminate unproductive regulatory burden. Community banks are already heavily regulated with federal, state, and private audits. Community bankers strive to meet goals for their community, but they would continue to do that regardless of any regulatory demand such as CRA. Many small-town and rural communities, where larger financial institutions will not venture to go, could not survive without the small-bank. Easing regulatory burden will free our hands to provide better service to ALL our customers.

Thank you for your consideration.

Sincerely yours,

M. Paul Haynes, Jr.
Chairman and CEO