Sevier County Bank
August 25, 2004
Mr. Bob Feldman
Executive Secretary's Office
550 17th St. NW
Washington, DC 20434
Re: Comment on CRA proposal
Dear Mr. Feldman:
As a small community bank, (Sevier County Bank, Sevierville, Tennessee)
we support raising the CRA small institution threshold to $1 billion
with a new community development criterion that would provide us
with a choice among community-based lending, investment and service
activities.
In our earlier comment letter, we expressed our concern regarding
the unnecessary regulatory burden the $250 million limit will cause.
During this phase in the growth of our bank, the cost of this detailed
regulation at $250M is too high and hurts earnings considerably.
This still rings very true.
Regulatory burden
is hurting all community banks – ours and
those across the nation. As community banks, we are the heart of
our communities. We are the ones reinvesting in our communities in
many ways, even though all those ways are not considered in an exam.
Once again, we support raising the CRA small institution threshold
to $1 billion and adding a new community development criterion that
would provide us with a choice among community-based lending, investment
and service activities.
Thank you for listening to the comments you received on your first
proposal request. Please consider our comments again.
Sincerely,
W.S. Brown
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