FDIC Federal Register Citations

August 12, 2004

Mr. Robert E. Feldman
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Dear Mr. Feldman:

Re: Proposed Revisions to the "Small Bank" Community Reinvestment Act Stream1ine Evaluation

As a community banker, I strongly endorse the FDIC's recommendation to increase the asset size limit of banks eligible for streamlined small bank CRA examination along with the elimination of the separate holding company qualification.

Increasing the size of banks eligible for the small bank streamlined CRA examination does not relieve banks from CRA responsibilities. Since the survival of many community banks is closely intertwined with the success and viability of their communities, the increase will merely eliminate some of the most burdensome requirements. The proposed increase to $1 billion in asset size to qualify for a streamlined evaluation better reflects the current demographics in the banking industry.

A separate Community Development Test which would give the Bank credit for its efforts to help low and moderate individuals and/or geographies, while not requiring investments that are not available to banks our size, would be a more equitable way of monitoring our compliance with CRA requirements.

Making it less burdensome to undergo a CRA exam will not change our Bank's way of doing business. The removal of a separate Lending, Investment, and Service test would not change our efforts within our community.

At Chicopee Savings Bank, we will remain committed to complying with the spirit as well as the requirements of the Community Reinvestment Act.

Sincerely,
William J. Wagner
President