FDIC Federal Register Citations

September 20, 2004

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

Re: RIN 3064-AC50

Dear Mr. Feldman,

I am a Senior Vice President of State Bank of Southern Utah, located in St. George, Utah, the largest community served by State Bank with approximately 50,000 residents. Our Bank is the sole subsidiary of our Bank Holding Company and is approximately $375 million in total assets and became a large bank for CRA purposes on January 1, 2003. I strongly support the FDIC’s proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion. This would greatly relieve the regulatory burden imposed on many small banks including our bank which under current regulations requires us to meet the same standards imposed on the nation’s largest banks.

When our bank went over the threshold and had our first large bank examination, there were massive new reporting, monitoring and investment reporting requirements placed upon us. We had dramatically increased the number of hours and efforts spent on CRA activities but because of stringent reporting requirements were not acknowledged for the great efforts that had taken place. I believe that raising the threshold to $1 billion would allow small banks to maintain the focus on lending to individuals and businesses in our small communities which is an important part of and consistent with the purpose of CRA.

Since much of our banking activities are located in rural Southwestern Utah, we would support the inclusion of rural services and activities as part of the community development definition as long as the FDIC provides a definition of “rural” that will be acceptable and will include all residents of rural areas.

In conclusion, I believe that the FDIC proposal will help streamline the regulatory burden associated with CRA and will allow small banks to concentrate more on the CRA efforts that really matter in the small communities that we serve instead of concentrating all of our efforts and dollars on the reporting and monitoring of CRA activities.

Sincerely,

Kim Christensen
Senior Vice President
State Bank of Southern Utah
395 East St. George Blvd.
St. George, UT 84770