FDIC Federal Register Citations

SCOTT VALLEY BANK

From: Timothy S. Avery
Sent: Tuesday, August 17, 2004 3:07 PM
To: Comments
Subject: RIN number 3064-XXXX

To Whom it May Concern,

Please accept this correspondence as Scott Valley Bank's comment of support for the proposed revisions to 12 CFR 345, implementing the Community Reinvestment Act (CRA) that would: a) change the definition of "small bank" to raise the asset size threshold to $1 billion regardless of holding company affiliation; b) add a community development activity criterion to the streamlined evaluation method for small banks with assets greater than $250 million and up to $1 billion; and c) expand the definition of "community development" to encompass a broader range of activities in rural areas.

Our support of this proposal is predicated on the belief that the recommendations for change to consider involvement in rural communities will recognize the many and varied positive influences small banks have on the communities they serve. This represents a very "real" approach to measurement of Community Reinvestment and the essence of its original intent.

The focus should be on pragmatic review of activities which support not only the lending activities in Low and Moderate income service areas and specific targeted investment and service contributions, but also services that provide benefit to entire communities, when significant percentages of the general population of a community meet similar criteria.

Recognition of the fact that banks under $1Billion in assets are truly "small" banks is long overdue. Please accept this bank's support of the current FDIC proposal.

Sincerely,

Timothy S. Avery