April 13, 2012
Our bank is thankful for the ability to deregister our shares and stop preparing the required federal filings. However, we are diassapointed that the SEC has chosen to require that we make one more 10-Q filing while waiting for the 90-day period before the filing is effective. Current companies with less than 300 shareholders who file a Form 15 may immediately suspend federal filings. It makes no sense to not afford this flexibility to banks like us who have more than 300 shareholders but less than 1,200. The law has been changed to increase the limit for deregistration from 300 shareholders to 1,200. The law should be applied. I'm confident that was the intent of lawmakers who overwhelmingly passed it. Requiring banks like us to file one more 10-Q is pointless and a continued waste of time and money.