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FIRST CITIZENS NATIONAL BANK
September 17, 2004
Robert E. Feldman, Executive Secretary
Attention Comments/Legal ESS.
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429
Dear Mr. Feldman:
As a community banker for more than four decades, I have witnessed
many changes in the regulatory environment. Many of the' rules, laws and
regulations which govern our industry are certainly warranted and work
in the best interest of the industry as a whole as well as the customer
base we serve. On occasion they do not. With this thought in mind, I
join my fellow community bankers throughout the nation in strong support
of the FDIC's proposal to increase the asset size limit of banks
eligible for the streamlined small bank CRA examination. The
proposal will greatly alleviate unnecessary paperwork and examination
burden without weakening our commitment to reinvest in our communities.
Reinvesting in our communities is something we do everyday as a matter
of good business.
It is important to remember that the streamlined CRA exam is not an
exemption from CRA. Banks subject to the simplified CRA exam are still
fully obligated to comply with CRA. Many community banks (especially
those in rural areas) have to invest in regional or statewide mortgage
bonds or housing bonds and the like to meet CRA requirements. These
investments may benefit other areas of the state or region but they
actually take resources away from the bank's local community. For this
reason, I find that the FDIC's proposed community development
requirement for banks between $250 million and $1 billion is more
flexible and more appropriate than the large bank investment test. The
advantage to this proposal is that it continues to focus on community
development; but considers investments, lending and services.
By easing regulatory burden, it will make it easier for community
banks like mine to continue to provide committed service to local
communities that few other financial service providers are willing to
do.
Thank you for considering my views.
Sincerely,
Katie Winchester
President, CEO & Vice Chairman
First Citizens National Bank, Dyersburg, TN
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