FARMERS & MERCHANTS BANK
September 2, 2004
Robert Feldman, Executive Secretary
Attn: Comments-Legal ESS
550 17th Street NW
Washington, DC 20429
Dear Mr. Feldman:
I would like to comment on the FDIC proposal to increase the large
bank threshold level for CRA reporting to $1 billion. I represent
a small ag bank in southeast Arkansas. Because we have acquired small
branches in our surrounding communities, we have recently gone over
the $250 million threshold.
I have recently
asked our CRA officer what this would mean to us in additional
reporting.
She responded by, bringing me several outline "summaries" of
the new requirements. She expressed concern that we may need to add
an additional employee to comply with this additional regulatory
burden.
Our community is just under 10,000 and population is declining.
Most towns in southeast Arkansas are experiencing similar declines.
Our local business leaders have formed a new organization called
Stuttgart Unlimited, to try to stop and hopefully reverse this trend.
Many of the tasks established by our group would benefit the entire
community, including our low to moderate income citizens. I am personally
in charge of addressing our housing needs. All of our local bankers
are involved in this project. If this is the type of activity anticipated
in a community development test, I will encourage you to include
that in your new proposal along with a $lbillion threshold.
As I consider the cost of adding an employee to sit in a office
and crank out paper work, I can't help but think, how that money
would be of far better use trying to maintain the economic viability
of our community.
Thank you for the opportunity to provide these comments.
Sincerely,
Don Pattillo
President & CEO
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