Federal Deposit
Insurance Corporation

April 2, 2004

Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC 20429-0001

Attn: Comment Section

RE: CRA Proposal

Dear Sir,

I have been following with interest the current regulation 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 and also eliminate the holding company size limit, which is currently $1 billion. As President and Chief Executive Officer of Bank of Wisconsin Dells, a $260 million bank located in Wisconsin Dells in the south central part of the state, I strongly endorse this Federal proposal because it would greatly reduce regulatory burden.

During this critical time for our economy, it is important for our sales people and loan officers to focus on developing business for the bank, not spending time documenting procedures and doing paperwork. We do not have the resources like the larger banks have for compliance issues like this. Even if we had the resources available to devote to CRA compliance, it would be resources not available for meeting the credit needs of the community. The small bank CRA examination process was an excellent innovation.

To really be fair, banks should be evaluated on the results in their communities and be measured against their peers, not banks hundreds of times their size. The proposed change recognizes that it is not right to assess the CRA performance of a $260 million bank like mine with the same exam procedures used for a $500 billion bank. While I feel the proposed increase is a good first step, the size of banks eligible for the small-bank streamlined exam really should be even higher, possible $1 billion.

One thing seems very ironic to me. The community activists seem oblivious to the costs and burden of regulations, yet they object to bank mergers that remove the local bank from the community. This is contradictory. If these groups want their local banks to remain in the community where they have better access to decision-makers, they must recognize that regulatory burdens are strangling smaller institutions and putting them at a competitive disadvantage.

In summary, I believe that this change is an important first step to reducing regulatory burden. While community banks still must comply with the requirements of CRA (and should), this increase in size will eliminate some of the most problematic and burdensome elements of the current regulation. Finally, I would like to urge the agencies to seriously consider raising the size of banks eligible for the streamlined exam to at least $1 billion or possibly a little higher in assets, to better reflect the current demographics of the banking industry. This would allow us to grow and expand without further regulatory burdens. Thank you for listening to my views.

Sincerely

Gary L. Gilliland
Chairman, President/CEO
Bank of Wisconsin Dells
716 Superior St.
Wisconsin Dells, WI 53965