FDIC Federal Register Citations

October 1, 2004

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

Dear Sir or Madam:

I am Credit Administration Officer of First Southern Bancorp, with offices located throughout central and western Kentucky rural communities with populations ranging from 600 to 15,000 residents. My bank holding company is $700 Million and subject to large bank CRA exams. I am writing to strongly support the FDIC's proposal to raise the threshold for the streamlined small bank CM examination to $1 billion without regard to the size of the bank's holding company. This would greatly relieve the regulatory burden Imposed on many small banks such as my own under the current regulation, which are required to meet the standards imposed on the nation's largest S1 trillion banks. I understand that this Is not an exemption from CM and that my bank would still have to help meat the credit needs of its entire community and be evaluated by my regulator. However, I know that this would lower my current regulatory burden significantly, allowing for the time spent in reporting our CRA activities to be reallocated to actively participating In actual CRA related activities.

I strongly support the FDIC's proposal to change the definition of 'community development from only focusing on low and moderate Income area residents to including rural residents As a bank predominantly located In rural communities, our rural lending activities do benefit our customer as well as our shared communities and the bank recognized for this loan activity.

In conclusion I urge the FDIC to adopt its proposal, with the recommendations above.

Sincerely,
Doug Daniel
Credit Administration Officer