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