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FDIC Federal Register Citations Comm Bancorp, Inc. September 22, 2005 Mr. Harrison Greene Mr. Greene: Pursuant to the request for comments on the Proposed Amendment to Part 363, I respectfully submit the following: As Chief Financial Officer of a $550 million publicly held bank holding company I applaud the efforts of the FDIC to relieve the burden of complying with Part 363 for smaller companies by increasing the threshold level to $1.0 billion. However, unless there is convergence of the rule makers, namely the SEC, with this definition of a small company then such efforts will go without merit as small publicly held companies considered non-accelerated filers are subject to comply with these same requirements under SOX 404 by 2007 despite being under the FDIC threshold. It does not appear logical that a publicly held bank should be subject to the internal control requirement based on SOX whereas a similar sized nonpublic bank is not subject to such requirements because it bases it compliance requirements on FDIC rules. Unlike any other industry, financial institutions are subject to significant burdens to develop policies and procedures which are already reviewed as part of the scope of a normal examination to assure safety to depositors. I hope that the banking regulators will remind the SEC of these burdens and that the SEC will consider amending their rules to align themselves with the FDIC. If you have any questions regarding the aforementioned comments, please feel free to contact me at 570.587.3421 extension 323.
Scott A.Seasock
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Last Updated 10/03/2005 | Regs@fdic.gov |