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First State Bank

Mr. Wayne H. Nielsen
President and Chief Executive Officer
First State Bank
200-204 Moorehead Avenue
Ida Grove, Iowa 51445

Dear Mr. Nielsen:

We have reviewed First State Bank's ("Bank") application filed pursuant to Section 362.3(b)(2)(i) of the Federal Deposit Insurance Corporation's ("FDIC") Rules and Regulations in which the Bank requests permission to directly engage as principal in an activity that is not permissible for a national bank. Specifically, the Bank requests permission to continue to hold three single-premium life insurance policies, which totaled $387,372 as of the date of your application, on Senior Vice President Mason J. Goodenow. For the reasons set forth in the enclosed Statement, the Bank's application was approved today, subject to the following conditions:

(1) That the Bank will neither acquire any additional life insurance policies of a type that are not permissible for a national bank nor modify the terms or conditions of the existing three such insurance policies, except for the redemption of the same, without first obtaining the FDIC's prior written approval.

(2) That the consent granted herein is based on the facts and circumstances presented or otherwise known to the FDIC in connection with this request. The applicant shall notify the FDIC of any significant change in facts or circumstances. The FDIC's action is conditioned on its ability to alter, suspend, or withdraw its approval in the event the facts and circumstances presented in the application change significantly.

If you have any questions regarding this matter, please contact Assistant Regional Director Randall T. Daughenbaugh or Case Manager Richard E. Allen of our Kansas City Regional Office at (816) 234-8000.


John M. Lane
Associate Director


Re: First State Bank
Ida Grove, Ida County, Iowa
Application For Consent To Conduct An Activity That May Not Be Permissible For A National Bank


Pursuant to the provisions of Section 24 of the Federal Deposit Insurance Act, an application has been filed with the Federal Deposit Insurance Corporation ("FDIC") by First State Bank, Ida Grove, Iowa ("Bank"). The application requests the FDIC's consent to hold three life insurance policies on an officer of the Bank. The cash surrender value of the policies currently totals $387,372.

The Bank, which meets the definition of "well capitalized" within the meaning of Part 325 of the FDIC's Rules and Regulations, is in compliance with applicable capital standards. In addition, the level of activity to be conducted and the manner in which the Bank will conduct the activity do not appear to pose a significant risk to the applicable deposit insurance fund.

Accordingly, based upon careful evaluation of all available facts and information, the Associate Director of the Division of Supervision has concluded that approval of the application is warranted.