FDIC Federal Register Citations

Owen County State Bank


April 2, 2004

Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Dear Mr. Feldman,

I welcome the opportunity to comment on the Economic Growth and Regulatory Paperwork Reduction act of 1996. Relative to the reducing the regulatory burden on banks, I have the following suggestions:

1. HMDA & CRA - Our bank with assets of approximately 180 million has recently become subject tc, the Home Mortgage Disclosure Act. We are located in the town of Spencer, Indiana, with a population of about 3,000. Our 2 branches are in even smaller communities. We are located approximately 20 miles from Bloomington In., which is the nearest MSA. Most of the loans we make are in Owen County, which has a population of 21,000. Perhaps banks under $250,000,000 in assets should be exempt from HMDA and CRA when located in homogeneous populations. The financial and staffing burden on small institutions is great.

2. Annual Privacy Notices If a privacy notice is given at time of the initial transaction, a new notice should not be required unless a change is made in the bank's privacy policy.

3. Flood Areas I understand the need for the Flood Determination, however, consideration should be given to the value of the land and also to the type of structures in the flood plain. If for example, there is an old shed in the flood plain the consumer would not rebuild, why should they be forced to pay the expense of flood insurance?

4. Equal Credit Opportunity Having the "Evident of Intent" for joint applicants is unnecessary when they axe signing a joint application.

Sincerely,
Gordon Wells President
Owen County State, Bank