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SECURITY NATIONAL BANK
March 10, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429
Dear Mr. Feldman:
This letter is to encourage the approval of the federal bank
regulators' proposal to increase the asset size of banks eligible for
the small bank streamlined Community Reinvestment Act (CRA) examination
from $250 million to $500 million and the elimination of the holding
company size limit. This proposal is most welcome as it would greatly
reduce the regulatory burden on small community banks like ours.
Security National Bank is a $224 million bank located in Durand
Wisconsin, population 1968.
Adjusting the asset size accurately reflects the significant changes
within the banking industry in the last 10 to 20 years. I previously
managed a Norwest Bank (now Wells Fargo Corporation), and am aware of
the amount of time and effort required to meet the big bank CRA
examination. It is neither reasonable nor fair to expect a community
bank to meet the same CRA examination requirements.
Those who object to increasing the limit do not understand the
consequences of continuing to treat all banks the same. Organizations
that are truly interested in maintaining the viability of community
banks understand the need to provide us regulatory burden relief. The
issue at community banks such as ours is to find people to lend money
to, not to find people that we don't wish to serve.
In summary, increasing the asset size of banks eligible for the small
bank streamlined CRA examination process is an important first step
towards reducing the regulatory burden.
Your consideration to this letter is appreciated.
Sincerely,
Gerald V. Weiner
President and Chief Executive Officer
Security National Bank
Durand, WI
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