FDIC Federal Register Citations

Premier Bank

September 30, 2004

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

Re: RIN Number 3064-AC50: FDIC Proposed Increase in the Threshold for the Small Bank CRA Streamlined Examination

Dear Sir or Madam:

I am Senior Vice President of Premier Bank, located in Jefferson City, Missouri. My bank is $425 million in assets and is not currently subject to the large bank CRA exam. I am writing to strongly support the FDIC's proposal to raise the threshold for the streamlined small bank CRA examination to $1 Billion without regard to the size of the bank's holding company. This would greatly relieve the regulatory burden imposed on many small banks such as my own under the current regulation, which are required to meet the standards imposed on the nation's largest $1 trillion banks. I understand this is not an exemption from CRA and that my bank would still have to help meet the credit needs of its entire community and be evaluated by my regulator. However, I believe that this would lower my current regulatory burden.

After researching RIN Number 3064-AC50, I believe the FDIC has proposed a major improvement in the CRA regulations, one that more closely aligns the regulations with the Community Reinvestment Act itself, and I urge the FDIC to adopt its proposal. I would be happy to discuss these issues further with you, if that would be helpful.

Sincerely,

Nancy K. Gratz
Senior Vice President