FDIC Federal Register Citations

April 9, 2004

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

Dear Sir:

As a community banker, I strongly endorse the bank regulators' proposal to increase the asset size for those banks eligible for the small bank streamline Community Reinvestment Act (CRA) examination from $250,000,000 to $500,000,000 and the elimination of the holding company size limit ($1,000,000). This proposal should greatly reduce regulatory burden. I am the President of the Valley Bank, a $105,000,000 bank located in Kalispell, Montana.

The small bank CRA examination was an excellent innovation. As a community banker, I applaud the agencies for recognizing community banks will never be successful unless they support individual and public programs within their immediate trade areas. Requiring community banks to comply with the requirements of large bank CRA evaluations, causes the cost and burdens to increase dramatically at the same time limiting the time which we have available to provide service to our customers and our communities, keeping in mind, the community bank can only serve the community in which it is located. Please excuse this bankers personal opinion that the CRA demands in place, have not been beneficial except to the customers of a possible unsuccessful rogue bank. The sole benefits, in our mind, has been a white collar welfare system for regulators provided through the mechanisms of regulatory agencies which have strayed from their original purpose of providing a "check and balance system" assuring an operation of safety and soundness.

Sincerely,

A. J. King
President
Valley Bank of Kalispell
Kalispell, MT