FIRST STATE BANK
March 8, 2004
Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429
Dear Sir:
My name is J. Pat Hickman. I am the President and CEO of the First
State Bank in Happy, Texas. I strongly endorse the 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. This proposal will truly reduce our regulatory burden.
Over the past 14 years, we have grown our total assets from
$10,000,000 to over $170,000,000 through the opening of several de
novo branches. For the first time, we are growing through an
acquisition of another bank, and following the merger we will have total
assets of just over $300,000,000.
With this acquisition, we will have 11 offices. Our largest branch
will have total assets of under $50 Million. We will be the only bank in
Happy and Sunray, Texas. Our loan-to-deposit ratio will be greater than
80% following the merger.
I tell you all of this to emphasize that we are serving our
communities-most specifically, we serve the low to moderate income
people because many of these communities are made up primarily of low to
moderate income folks. If we should ever close our bank in Happy or
Sunray, I don't look for anyone else to come in and take our place. Yet,
we are growing and purchasing another bank in order to achieve certain
"economies of scale" and quite simply, in order to survive, while trying
to provide a decent return to our shareholders.
By raising the CRA threshold, you will be helping the First State
Bank of Happy in a most significant way. For what it's worth, we do not
have, nor do we anticipate having any consumer activists saying that we
don't take care of our neighbors. Please call me, should you need any
further comment or clarification---and say hello to Mr. Powell---I
worked for him for almost ten years. Thank you for your time.
Sincerely yours,
J. Pat Hickman
President & CEO
First State Bank
Happy, TX
