FARMERS NATIONAL BANK
August 20, 2004
Communications Division
Public Information Room
Office of the Comptroller of the Currency
250 E. Street S.W.
Washington, D. C. 20219
Dear Sir:
The officers and directors of this bank are very adamant about
increasing the regulatory threshold from $250 million to $500 million,
considering inflation and growth we favor even a larger threshold to $1
billion.
Our bank feels raising of this threshold will enable our limited
staff to better administer and police recent and existing regulations
including:
1. Release of lending information under the terms of the new privacy
act.
2. Provide more time and attention in our efforts to service the
existing minorities and rural customers spread out over the large
territory we serve.
The consolidation and mergers of banks in the high end of the
threshold has created an untimely growth in the size of banks in the
lower end of the threshold. Many of these banks were under $250 million
prior to 1995 when the CRA regulation was passed and now those banks are
well above the $250 million size.
The regulatory burden of creating administrating and policing the
HMDA, U.S. Patriot Act and Gramm-Leach Bliley have dropped an avalanche
of paperwork on the smaller institutions and we feel this time and
paperwork has adversely affected the safety and soundness of some
institutions whom we feel should give a high priority to the safety and
soundness of their financial institutions.
Sincerely,
J. P. Hamilton
Board Chairman
Farmers National Bank
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