FDIC Federal Register Citations

Jefferson Bank of Missouri

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

Dear Sir:

My name is Mark Aulbur from Jefferson City, Missouri. I work for Jefferson Bank of Missouri, which is one of five banks in our small community with a population of 36,000. Jefferson Bank has total assets of $400 million and we are part of holding company based in Missouri that has total assets of $6 billion.

I am writing this letter to give support the current FDIC's proposal to raise the threshold in an effort to streamlined small bank's CRA examination. This change to $1 billion without regard to the size of the bank holding company will relieve the burden on all small banks both in cost and in manpower dedicated to these CRA examinations. This also would relieve the FDIC examiners for more time for examining other areas of the bank.

The investment test has been very hard for our bank because of the size of our community. Our bank like many other small community banks have had to look at regional investments because qualifying investments are not always available in a community of our size. These regional investments are not benefiting our community and I do not think this is what a lawmaker's intended when CRA was original enacted.

Jefferson Bank has always been a leader in our community in it's lending. We lend to all area of our assessment area including the low-moderate income census tracts. As a small community bank the majority of our loans are going to consumers and small businesses located in our assessment area. We also take pride in our employee's involvement in various clubs and civic associations of our community. Many of these groups do help the low-moderate income of our community. But even with our great lending record and our employees involvement because of the investment test we can not obtain the outstanding rating we once had.

I truly believe that the this new FDIC proposal for improving the CRA regulations will benefit not only our bank and other small community banks like us but also in the
end will benefit the customer that we serve in our small community.

Sincerely,
Mark J. Aulbur,
Compliance Officer J
Jefferson Bank of Missouri