Date:    4/6/99  1:43 PM

Subject: Comment on File NO. S7-30-98

Please accept the following comment on File NO. S7-30-98
     
Comment on File NO.  S7-30-98
     
I am writing in response to the SEC proposal to tighten filing 
deadlines.  I am a Controller of a $470MM community bank with an 
accounting department made up of six individuals including myself.   I 
am strongly against this proposal because I believe it will place an 
unnecessary reporting burden on my institution/department and many other 
similarly sized institutions/departments.  These more stringent 
deadlines will also increase my costs and may jeopardize the accuracy 
and completeness of the report.
     
There are several steps that are necessary in order to ensure an 
accurate SEC filing.  First the books need to be closed out for the 
quarter/year to be reported, once that is completed all of the report 
schedules need to be completed (e.g. Balance Sheet, Income Statement 
etc..).  After the schedules are completed the Management's Discussion 
and Analysis (MD&A) sections need to be updated.  After the report has 
been updated it needs to be reviewed and rewritten several times before 
we are satisfied with the numbers and the MD&A.  Once this point has 
been reached copies are sent to our SEC Legal Council and our External 
Auditors.  After at-least a week's time both the auditors and council 
make comments/corrections/suggestions, which need to be reviewed and 
changed if necessary.  When all parties are satisfied with the report 
contents the report needs to be converted into EDGAR format and then 
reviewed one final time before submission.
     
All of the above processes take up the full 45-day period on a quarterly 
basis and the full 90 days for the annual/10-K/Proxy.  Additionally, 
during these periods my staff is required to put in 60-hour workweeks in 
order to meet the current deadlines.
     
My department is also responsible for all other regulatory reporting in 
addition to SEC filings.  This reporting includes the following filings:
     
Federal Reserve FRY - 9C  and FRY-9LP 
FRY - 6    and FRY- 6A
FRY - 8
FRY - 11Q  and FRY 11I
FR2900
Federal Funds Daily Certification
     
FDIC   Quarterly Call Reports
   Summary of Deposits
   Quarterly Deposit Insurance Assessments
     
FHLB   Quarterly Collateral Certification/Qualified Assets Ratio
     
OCC   Annual Exam/Audit
     
All the regulatory reporting aside, my staff and myself still have the 
daily responsibilities and internal reporting requirements for our 
financial institution.   For all the above reasons I would like to 
reiterate my opposition to the proposal and ask that the SEC reevaluate 
their position, especially for smaller sized institutions like my own.
     
Thank you,
     
T. Benjamin Marsho
VP/Comptroller
First National Bank of West Chester
West Chester PA