From: Steve DeWitt
Sent: Monday, March 15, 2004 5:26 PM
To: Comments
Subject: Jan. 27, 2004 - Notice of regulatory review
Thank
you for giving us the opportunity to comment on this
most important
issue.
We
are in favor of any regulatory burden relief for a bank
with assets of
$150 million or less.
One regulation in particular that needs consideration is
the Home Mortage
Disclosure Act (HMDA). Being a new reporter effective
this year, we feel
HMDA should have a small-bank rule similar to CRA or a
much higher asset
exemption above the current $33 million level. Another
example of a basis
for exemption when rural counties are included in an MSA
would be to look at
the percentage of a bank's loan portfolio made to the
primary MSA county and
establish a floor limit for reporting based on that
percentage.
Another part of HMDA which appears to be outside of the
intent of the rule
is the definition for refinancing. It doesn't seem to
make much sense to
report the refinancing of a commercial or agriculture
loan that is only
partially secured by a dwelling.
Please consider these comments during the evaluation
process. We feel they
make a lot of sense for a small rural bank such as ours.
Sincerely,
Steven DeWitt
Sr. Vice President and Cashier
The First State Bank of Burlingame
Burlingame, Kansas