FDIC Federal Register Citations

From: GregS@GRABILLBANK.COM [mailto:GregS@GRABILLBANK.COM]
Sent: Wednesday, March 31, 2004 8:04 AM
To: Comments
Subject: EGRPRA burden reduction comment

As a 24 year member of the banking industry, I appreciate this effort to
attempt to lessen government regulatory burden. There are a myriad of
regulations that are extraordinarily burdensome and overly complicated but
the likelihood of repeal is almost zero. So, perhaps the best we can hope
for is some positive "tweaking" in some of the regulations.

I suggest considering changing one requirement regarding the issuance of
mortgage application disclosures. Specifically, it would be very helpful if
the mandatory issuance period is extended from the present requirements
(immediate if "in person" application and 3 days if "mail" application) to 5
days.

As a community bank, we are competing against the large money center bank,
mortgage brokerage firms, and tax-exempt credit unions and it is a battle to
stay competitive. One way to accomplish this is to keep our overhead
expense low. In order to do this, most of our staff wears multiple hats so
it is very difficult to respond within the current required time period.
Occasionally, we fail to do so resulting in a violation of the banking
regulations - something we do NOT want to do.

So, your consideration in this regard will be greatly appreciated.

Greg Smitley
Senior Vice President