FDIC Federal Register Citations

September 20, 2004

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

Re: RIN Number 3064-AC50

Dear Mr. Feldman:

Our bank is a 130-year-old community bank with approximately $740 million in assets serving six mostly rural counties in upstate New York. We have, throughout our history, regarded ourselves as a strong corporate citizen and our position in that regard was long before the passage of CRA legislation some 30 years ago. I might add that in those thirty-plus years, no one except college students doing papers has asked to see our CRA public file.

Although we have a national charter, we strongly support the FDIC's proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of the bank's holding company. This would greatly relieve the regulatory burden currently imposed on small banks, which are now required to meet the same standards imposed on the nation's largest $1 trillion banks. In our specific case, we estimate an annual expenditure of 2400 hours and a cost of $50,000 for us to compile data in support of our community reinvestment activities.

We also support the addition of a community development criterion to the small bank examination for larger community banks, but we believe that the FDIC should adopt its original $500 million threshold without a community development criterion. The new community development criterion should be applied only to banks greater than $500 million up to $1 billion. As field examiners know, it has proven extremely difficult for small banks to find appropriate CRA qualified investments in their communities.

We thank you for recognizing that "one size does not fit all" when it comes to CRA, and we urge you to adopt your proposal.

Sincerely yours,

Alfred S. Whittet
President & CEO