FDIC Federal Register Citations

Worth National Bank

From: Bob Semple
Sent: Friday, August 20, 2004 11:28 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Sirs,

As the CEO of a $300M bank I am concerned about the community investment requirement proposed for a bank our size. My concern is that we do not have the expertise to evaluate a complex equity housing project nor do we have the amount of capital required to compete with the larger banks for these type of projects which tend to be larger in size than we can reasonably accomodate. So, how do we fulfill this requirement? We do have an SBIC investment and a CDC investment. Will those fulfill the new criteria? If so, I am ok with this. If not, I would recommend increasing the samll bank limit to $500M. At that size we could afford to hire the expertise and have enough capital to compete for the larger deals.

Bob Simple
Chairman and CEO
Worth National Bank
Lake Worth, Texas