FDIC Federal Register Citations

Security First Bank of North Dakota


April 7, 2004

EGRPRA
Office of the Vice Chairman
550 17'th Street, NW MB-6000
Washington, D.C. 20077-5468

Dear Sirs:

The regulations facing small banks today are incredibly complex and need to be simplified and streamlined. Complying with any one regulation, while difficult, is not impossible. However, when you look at the regulations as a whole, they are absolutely overwhelming and next to impossible for any community bank to comply with.

Each regulation needs to be completely reviewed, and then either eliminated or simplified to insure easy compliance. As a part of that rule, a careful look should be given at carving out exemptions or simplified compliance procedures for smaller banks. Smaller banks simply can not afford the staff to stay on top of all of today's rules and regulations.

Also, as you are reviewing the regulations, please keep in mind that the community banks in America are not responsible for the consumer abuses practiced by the larger banks that led to these regulations. Please keep in mind the disproportionate burden these regulations place on small banks. Please keep in mind that it is not fair to subject a small bank to the same regulations as a behemoth like Citibank. And please keep in mind that the larger banks now can and do operate as though they are above the law and they do not have to worry about compliance. For a small bank a fine for failure to comply with a law or regulation is a big deal, but for Citibank, a $10,000,000.00 fine is really only equivalent to the income they earn in minutes.

Respectfully
James M. Goetz
Chairman & CEO