FDIC Federal Register Citations

From: Jeanne Sanden
Sent: Monday, February 09, 2004 12:33 PM
To: Comments
Subject: Proposed Comments-12 CFR Part 345-Community Reinvestment Act Regu lations

I work for a Bank Holding Company that owns 12 banks in three states (Minnesota, North Dakota and Wisconsin), with asset size ranging from $24 Million to $232 Million. I would like to lend my support to the current proposal, which redefines the definition of a small institution from $250 Million ($1 Billion Holding Company) to $500 Million. Currently, the Holding Company is nearing the $1 Billion mark. In a few years with the current definition, the twelve banks will incur significant regulatory burden under the large institution definition. Many of the banks would have to add staff with the increased recordkeeping requirements. Also, it would be very hard to get a Low/Satisfactory rating on the Investment Test.

Jeanne Sanden
Vice President
Community Bank Of The Red River Valley
1413 Central Avenue NW, East Grand Forks MN