FDIC Federal Register Citations

From: McKay, Cathy [mailto:CMcKay@palosbank.com]
Sent: Monday, August 16, 2004 11:25 AM
To: Comments
Subject: RIN 3064-XXXX

I am supportive of raising the small bank reporting asset size for CRA from $250M to $1B. There are a significant number of community banks with asset sizes between $250M or $500M and $1B who are currently subjected to playing on the same field as their big brothers. Community banks are, by their nature and definition, dedicated to the communities in which they are located and whom they serve. Community bank resources cannot be equated with the resources available at the larger institutions (i.e. > $1B). The regulations as they stand, have not been fairly recognizing the divergence in the nature of these two types of facilities. Raising the limit for small bank reporting to $500M does not go far enough--we need the more appropriate distinction of small bank versus large bank set at $1B. Thank you for your consideration.