Comment on CFPB-2012-0033-0019

I write today to comment on the upcoming changes to the TILA. We are concerned about the definition of a "Small Servicer". Even with some exceptions, this is a trmendous burden on small, rural banks like ours. Please exempt small institutions like ours from these changes. We are considering dropping our home products completely due to vast new regulations. There are very few lenders active in our part of rural Nebraska. This would dramatically and negatively impact our home loan market and consumers here. First the Periodic billing statements, with margins shrinking this is a large increase in overhead for home loans. Software, training, and compliance costs make this prohibitive. Second, just as with the statement requirement this increases overhead and forces much earlier pricing of these adjustments. This can result in a serous mis-match of assets and liabilities. In larger lenders this may be a simple adjustment of the balance sheet assets, but in small banks like ours we can only take what our market offers. We have mush fewer chances to manage these mis-matches for funding. Therefore, the consequences of mis-matches are more dramatic and dangerous. Finally, prompt crediting is already our practice. PLease be reasonable about after hours and weekends. With limited staffing and resources it is more difficult to process payments after hours and on weekeends. We have one (yes, one) EDP operator who can enable our systems, and if he is off this weekend we can process until the next business day. Please allow exceptions for small banks on this.