FDIC Federal Register Citations

October 5, 2004

Robert E. Feldman, Executive Secretary
Attention: Commercial/Legal ESS
FDIC
550 17th Street NW
Washington D.C. 20429

Dear Mr. Feldman,

As a community banker, I am writing in support of the proposal to raise the asset limit for the “small bank” streamlined CRA examination. In the total banking picture, we are definitely still a “small” bank even as we edge into the large bank category according to current regulations. Under those regulations, we are about to become subject to a very substantial increase in regulatory burden as the result of a very limited advance in our financial position. The strain on limited resources, especially at a time when other regulatory demands continue to expand greatly, would be considerable. While viewing the proposal favorably, we do oppose the addition of new community development criterion, and for the same reasons. Raising the limit allows us to continue to perform as we have been. Adding the community development section diminishes our ability to do that by creating a significant burden which is not a reflection of any increased opportunity to meet new standards.

We have always taken pride in our CRA performance which has resulted in consistent Outstanding ratings and we have been gratified by the good business opportunities it has provided. The suggestion that our community would be less well served by us through a proposal that only seeks to keep pace with the evolving banking environment is not creditable.

Thank you for the opportunity to comment.

Sincerely,

Thomas E. Unsworth
Senior Vice President, Mortgages
CRA Officer