FDIC Federal Register Citations

Bartow County Bank

January 20, 2004

FDIC
Legal
550 17th St. NW
Washington DC 20429

Gentlemen:

On behalf of Bartow County Bank located in Cartersville, Georgia, I would like to respond to the proposed changes to the Community Reinvestment Act referenced in the FDIC release #PR-5-2004 dated January 20, 2004.

I believe that in the ever-changing banking environment of today, faced with larger and larger bank mergers and acquisitions, that the proposed increase in the asset size definition of small banks is both timely and appropriate.

As more and more community banks quickly attain the current asset size of $250,000,000.00 that is now used to determine large banks versus small banks, I believe that the proposed asset size increase to $500,000,000.00 is more practical for both record keeping purposes on the bank level, as well as the monitoring and compilation of information by the FDIC.

I would, however, like more information on exactly what information would continue to be required by banks that would be classified as a “small” bank under the proposed increase in regard to their small business and farm loans. The final paragraph of the above referenced release suggests that the CRA disclosure statement should contain the number and amount of those types of loans by census tract. A clarification on record keeping requirements and reporting for banks if this proposal is implemented would be appreciated.

Thank you for allowing comments from those of us most directly affected by proposed regulation changes.

Sincerely,

Bartow County Bank

By: _________________________
Laura M. Willbanks, VP/Loan Op./Compliance