FDIC Federal Register Citations

From: David McNamara [mailto:Dmcnamara@newtownsavingsbank.com]
Sent: Tuesday, September 07, 2004 11:23 AM
To: Comments; John Martocci
Subject: RIN Number 3064--AC50

I have two comments:
I would love to see the $1billion figure adjusted annually to account for intrinsic asset growth, such as 2% a year. With mortgages increasing in amount due to house price inflation, asset size has been growing exponentially, many banks will quickly cross this threshold.

Second, I know there is a comment regarding expanding range of community development services in rural areas. Our Bank is always frustrated because we have little if any low-mod income geographies in our assessment area. We would love to do some projects outside the assessment area but feel constrained by the current definition of community development which suggests you can only get CRA credit for loans within your assessment area.

Finally, our Bank is strongly supportive of the effort to increase the threshold to one billion dollars.

David R. McNamara, Vice President Compliance Officer