FDIC Federal Register Citations

Darby Bank & Trust Company

October 19, 2004

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

Re: RIN Number 3064-AC50

Dear Mr. Feldman:

I am the CFO of Darby Bank & Trust Co. located in Vidalia, Georgia. Vidalia is town of 10,500 residents located in South Georgia. Darby Bank & Trust Co has assets of $485 million and will soon be subject to the large bank CRA exam. I am writing in support of the FDIC’s proposal to increase the threshold for the small bank CRA exam to $1 billion without regard for the size of our bank holding company.

We strongly support this proposal as it relieves a regulatory burden imposed on small banks under the current regulation, which are required to meet the standards imposed on the nation’s largest banks. We understand that this will not exempt the bank from CRA and that we would still be required to help meet the needs our community. We support CRA lending in the communities we serve, however we feel that it is unfair to be subjected to the same regulatory burden as banks with assets of $1 trillion and greater.

In summary, we are in favor of the FDIC’s proposed improvement in the CRA regulations to increase the CRA streamlined small bank threshold to $1 billion. If you have any questions or would like to discuss further, please contact the undersigned.

Sincerely,

Chris M. Bond
Sr. Vice President & CFO