FDIC Federal Register Citations

Cameron State Bank

October 14, 2004

Robert E. Feldman, Executive Secretary
Attn: Comments/Legal ESS
550 17th Street, NW
Washington, DC 20429-0002

Re: Proposed Amendments to CRA

Dear Mr Feldman,

In FIL -108 — 2004, your agency asked banks to comment on the amendments that are proposed to the Community Reinvestment Act. One of these proposed amendments would change the definition of a small institutuion to mean an institution with total assets of up to $1 billion.

I have been in banking for over 30 years and presently serve as a Sr. Vice President for Cameron State Bank. I have been involved with CRA for many years and continue to deal with the increased regulatory burden of data collection and reporting on its small business, small farm and community development loans. We, as a community bank, make the majority of loans inside our assessment area, which can be very burdensome. This is a trait that the majority of community banks are required to do on a day to day basis.

The CRA examination processyis another issue that needs to be addressed. Under the large bank CRA examination process, the investment test is difficult for a community bank to attain a satisfactory rating. We find ourselves competing for suitable investments in our market with billion ' dollar] regional and national banks that have an unfair advantage due to their size. They have the ability to spend whatever it takes to get those investments. The smaller banks are then at a disadvantage during exam time.

It is imperative that a change is needed in the definition of a small institution to one with total assets of up to $1 billion without regard to the holding company assets.

Thank you for entertaining this issue of great importance and would appreciate any help that you could do to make this happen.

Sincerely

J. Lyles McDaniel
Sr. Vice President