EXHIBIT 99.7


                      [LETTTERHEAD OF FERGUSON & COMPANY]


                                 March 21, 2000




Board of Directors
Community Bank of Central, Texas ssb
312 Main Street
Smithville, Texas 78957


                     Plan of Conversion, Subscription Rights

Dear Directors:

         Terms used in this letter not  otherwise  defined  herein have the same
meanings  for such  terms  in the Plan of  Conversion  adopted  by the  Board of
Directors of  Community  Bank of Central  Texas,  ssb  ("Community  Bank" or the
"Bank"),  under which the Bank will convert from a mutual savings association to
a stock savings  association  and issue all of the  Association's  stock to CBCT
Bancshares,  Inc. (the "Holding Company").  Simultaneously,  the Holding Company
will issue shares of common stock.

         We  understand   that  in  accordance  with  the  Plan  of  Conversion,
Subscription  Rights to purchase  shares of Common Stock in the Holding  Company
are to be issued to (1) Eligible Account  Holders,  (2) The Bank's tax qualified
employee  plans,  (3)  Supplemental  Eligible  Account  Holders,  and (4)  Other
Members.  Based solely upon our observation that the Subscription Rights will be
available to such parties without cost, will be legally  non-transferable and of
short  duration,  and will afford such parties the right only to purchase shares
of Common Stock at the same price to be paid by members of the general public in
the Community Offering, but without undertaking any independent investigation of
state or federal  laws or the  position of the  Internal  Revenue  Service  with
respect to such issue, in our opinion:

         (1) The Subscription  Rights will have no  ascertainable  market value;
and

         (2) The price at which the Subscription Rights are exercisable will not
be more or less than the pro forma market value of the shares upon issuance.

         Changes  in  the  local  and  national  economy,  the  legislative  and
regulatory  environment,  the stock market,  interest  rates and other  external
forces (e.g., natural disasters or significant global events) occur from time to
time and may  materially  affect  the value of  thrift  stocks as a whole or the
Holding Company's value. Accordingly, no assurance can be given that persons who
subscribe to shares of Common Stock in the Conversion will thereafter be able to
sell such shares at the same price paid in the Subscription Offering.

                                                 Sincerely,



                                                 /s/ Charles M. Hebert

                                                 Charles M. Hebert
                                                 Principal