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| DAVID E. TATUM Vice President |
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June 22, 2007
Randolph A. Moore, III
Alston & Bird LLP
1201 West Peachtree Street
Atlanta, Georgia 30309
Dear Mr. Moore:
The Federal Reserve Bank of Atlanta, acting pursuant to delegated authority for the Board of Governors of the Federal Reserve System and having considered the relevant statutory factors, has today approved the application by Security Bank Corporation, Macon, Georgia (Applicant), to merge with First Commerce Community Bankshares, Inc., Douglasville, Georgia (Bankshares), and thereby acquire First Commerce Community Bank, Douglasville, Georgia (Bank), pursuant to section 3(a)(5) of the Bank Holding Company Act.
In taking this action, the Federal Reserve System has relied on the representations and commitments made by Applicant in its application for approval. Every effort should be made to meet these representations and commitments since any deviation could be regarded as a violation of the terms upon which the System’s action was premised, and could elicit further action under the Bank Holding Company Act or the Financial Institutions Supervisory Act. If, despite your best efforts, deviations seem likely, you should immediately notify this Reserve Bank. We would then be available to discuss the matter with you.
The transaction may not be consummated before the 15th calendar day following the date of this letter or after three months from the date of this letter, unless such period is extended by the Federal Reserve System. In connection with these provisions, advice of the fact of consummation should be given in writing to the Reserve Bank.
Should you have any questions concerning this matter, please contact Stacey L. Bonner of our staff at (404) 498-7115.
Very truly yours,
cc: Board of Governors
Georgia State Banking Authority
U.S. Department of Justice
Federal Deposit Insurance Corporation – Washington
Alaina Gimbert, FRB Atlanta