From:
Cheryl Marzolf [mailto:Cmarzolf@perkinsstatebank.com]
Sent: Monday, April 19, 2004 1:44 PM
To: Comments
Subject: EGRPRA Burden Reduction Comments
Two quick comments about two regs:
HMDA
I would like for banks with a branch in an MSA exempt from reporting
when 5% or less of the previous year's reportable loans were in
the MSA. Because we own a single branch in an MSA, we are reporting
nearly 500 records on our LAR. Only 12 records were in the MSA,
the others were in rural Florida. I suspect the outside MSA data
is not very useful. Consider limiting the reporting requirements
to inside MSA loans only.
TRUTH IN LENDING
Delete the requirement for oral disclosure of APR (Section 226.26).
