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FDIC Federal Register Citations From: Anderson, Monica M [mailto:MAnderson@hubank.com] I would like to comment on the proposed change to the Annual Independent
Audits and Reporting Requirements of 12 CFR Part 363. I support the raising
of the threshold from $500 Million to $1 Billion for internal control
assessments by management and external auditors. If the threshold is raised
a financial burden will be removed for several Community Banks. Community
Banks with assets above $500 Million have a substantial financial costs
associated with FDICIA compliance...this includes external auditors,
additional test work and personnel. Community Banks will continue to
evaluate the effectiveness of internal controls, document these results and
report them to management and the Audit Committee. The raising of the
threshold will not result is less effective internal controls. It would be very helpful and beneficial if this ruling can be finalized
in a timely manner. Several requirements of FDICIA are completed each
quarter and it would be helpful and cost effective to know as timely as
possible if this testing needs to be continued or not. Thank you,
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Last Updated 08/16/2005 | Regs@fdic.gov |