FDIC Federal Register Citations

Wyoming County Bank

October 6, 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-ACSO

Dear Mr. Feldman:

Wyoming County Bank wholly endorses the FDIC's efforts to reduce regulatory burden and would encourage the FDIC to expand these efforts further. 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.

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 your time and we urge you to adopt your proposal.

Sincerely,
Jon J. Cooper