OUACHITA INDEPENDENT BANK
September 17, 2004
Mr. Robert E. Feldman (VIA E-mail)
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
RE: RIN 3064-AC50/CRA STREAMLINED EXAMINATION
Dear Mr. Feldman:
I am writing to you today to express my support of the proposal
that would increase the CRA small bank examination threshold to $1
billion. Ouachita Independent Bank is a $240 million bank, and like
so many other institutions similar in size, we are rapidly approaching
the current large bank mark. As you know, when an institution reaches
large bank status, the reporting, monitoring and investment program
must be completely reorganized. Such reorganization is a huge undertaking
for an organization such as ours.
Our current regulator burden is significant to say the least. Large
bank CRA standards will add an enormous amount of training and work
to our staff. Please consider the proposed increase to $1 billion,
which will allow us and numerous other banks to focus on serving
our customers and our communities.
Thank you for taking my views into consideration.
Very truly yours,
OUACHITA INDEPENDENT BANK
Jeremy Harrell
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