FDIC Federal Register Citations

October 18, 2004

Robert E. Feldman, Executive Secretary
Attention: Comments / Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N. W.
Washington, DC 20429

Re: Proposed Amendments to CRA-RIN 3064-AC50

Dear Mr. Feldman:

The Federal Deposit Insurance Corporation has requested commentary from banks on the proposed revisions to the definition of a “small bank”. It would extend an institution’s total assets to $1 billion without regard to the hold company assets.

The small but growing community bank I currently work for recently became a “large bank” less than two years ago. Like many other smaller banks in the “large bank” category, we find it difficult to compete with banks whose assets provide multi-billion dollar resources that can easily and regularly outbid us. The “small bank” category would help us to meet the credit need of the communities we serve.

Another proposal to be expanded would be the flexibility of community lending, investment, and services. This would allow institutions to meet needs through qualified investments, community development services, or community development lending. This expanded flexibility would only require the institutions to be engaged in one or more of the activities based on the opportunities of the bank and market.

Our institution is in favor of the proposal to revise the definition of a “small bank” to raise the asset size threshold to $1 billion without regard to the assets of the holding company.

Thank you for considering my comments on this matter.

Sincerely,

Gina Finley
Supervisor