FDIC Federal Register Citations

Cameron State Bank

October 20, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW Washington, DC 20429

Re: Proposed Amendments to CRA

Dear Mr. Feldman:

I have been informed that your agency has requested banks to submit comments in regards to the Commmunity Reinvestment Act (FIL-108-2004). This proposed amendment would change the definition of a small institution to a bank with total assets up to 1 billion.

I serve as a lending officer and Senior Vice-President at Cameron State Bank and feel that this amendment would be beneficial to the smaller banks. Our bank has had to deal with increased regulatory burdens and reporting on small businesses, farms, and community development loans for the past 2 years. This has caused burdensome work on community banks in regards to loans within our assessment area.

Also, the CRA examination process is much more difficult for a community bank to attain a satisfactory rating. We are forced to compete for suitable investments with larger billion dollar regional and national banks. They have the resources to spend additional funds to do whatever it takes to obtain a market advantage over smaller institutions.

I am very much in favor of changing the definition of a small institution to one totaling assets of 1 billion without regard to the holding company assets.

Thank you for considering this matter.

Sincerely
Elmo Sartin
Sr. Vice-President Regional Manager