FDIC Federal Register Citations

Germantown Trust & Savings Bank

September 13, 2004

FDIC

As President of a small Community Bank in Southern Illinois, I am very much in favor of changing the "small bank" assets size for CRA. I feel no matter what size a bank is in rural areas of Illinois, we are either involved in community reinvestments or you will not stay in business. I applaud the FDIC and OTS for these efforts in raising the threshold from 5250,000,000.00 to one billion.

Naturally customers and concerned groups should be concerned that the level of service by the Bank and its employees will change. Quite frankly it will not and cannot for the reasons stated above,

The main reason for change is the amount of paperwork a large bank is forced to submit, the collections of data, purchase of software and possible employment of workers to run the program. Let's understand the reason we have CRA — will large bank data change the job small banks do everyday — being involved with the community they serve.

We are already inundated with paperwork that very much affects the bank but not the service we provide.

Sincerely,

Dale G. Deiters CEO/President
Germantown Trust & Savings Bank