FDIC Federal Register Citations

From: Larry Emory [mailto:LEmory@ctbonline.com]
Sent: Thursday, September 02, 2004 10:59 AM
To: Comments
Subject: RIN 3064-AC50

I desire to comment on the proposed changes to the CRA definition of small and large banks as proposed in RIN 3064-AC50. I am the CRA Officer of Community Trust Bank with our home office in Choudrant. Louisiana with assets of $400 million. We do everything we can possibly do to meet the investment, lending, and service criteria in order to receive an outstanding rating on an exam. However, we find it difficult to compete, especially in the investment test, because of our small assessment area. We serve only three parishes in the state, Lincoln, Union, and Ouachita. We are primarily a rural assessment area with one MSA and scattered small towns. Therefore, we are at a disadvantage to larger multi-state banks in our assessment area since they are able to make investments in larger metropolitan areas outside our assessment area. We are limited in making legitimate CRA investments because the opportunities just simply do not exist in our three parish area.

Therefore, we support the change from $250 million to $1 billion in assets to distinguish between small and large banks. We also support the distinction of community development activity in rural areas because of the makeup of our assessment area.

If you want further input or more explanation, please let me know. Thank you.

Larry Emory
CRA Officer
Community Trust Bank
1900 Farmerville Hwy
Ruston, LA 71270
318-254-2023
lemory@ctbonline.com