Via email

From: Julie Carnahan 
Sent: Tuesday, August 05, 2003 8:46 AM
To: regs.comments@federalreserve.gov; Comments;
regs.comments@occ.treas.gov; regs.comments@ots.treas.gov

Subject: EGRPRA

We are a rural 40 million bank in Saunders County, Nebraska, with a 104 year
old charter and over 100 years experience in our loan officers.  The
regulation that requires us to obtain an outside/certified appraisal on
loans of $250,000 and more is out of date and a burden.  The $250,000
threshold has been the same since the regulation was put on the books many
years ago with no allowance for inflation.  It requires us to spend $1000 to
$1500 on a farm appraisal to tell us less than what we knew about the value
of the land at the time the loan application was received.

John C. Barry
Oak Creek Valley Bank
PO Box 8
Valparaiso, NE  68065