I work for a bank ($24 million in assets) in a holding company that
owns 12 banks in three states (Minnesota, North Dakota and Wisconsin),
with asset size ranging from $24 million to $232 million. I would like
to lend my support to the current proposal, which redefines the definition
of a small institution from $250 million to $500 million without any
regard to holding company asset size. Currently, the holding company
is nearing the $1 billion mark. In a few years with the current definition,
the twelve banks will incur significant regulatory burden under the
large institution definition. Many of the banks would have to add staff
with the increased record keeping requirements.
Thank you,
Paul Dornfeld
Vice President
Citizens State Bank of Waterville
Waterville, MN
