FDIC Federal Register Citations

State Bank of Southern Utah

From: John Westwood
Sent: Monday, August 30, 2004 11:20 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I am an officer in a mid-size $318 million deposit bank in Southwestern Utah. Many of the communities we serve have populations under 500 people. We also have branches serving those communities. We are profitable in those communities because we invest back into the communities. CRA is not only to provide housing in the outlying communities of the urban areas, but is about investing in those needed areas. We have a securities portfolio of $40 million that is primarily invested in smaller communites for essential purposes such as water, sewer, etc. These investments are passed over by other investors. The communities save thousands of dollars because we are willing to invest in the unrated small communities where CRA can make a difference. Yet, the last CRA exam rated our investments low. We will continue to invest in our small communities without oversight, and feel that the threshold should be increased to $1 billion. Maybe the threshold limit should be equal to the asset size of the largest credit union in the state where they are not subject to CRA. Many community activist groups would say increasing the limit would hurt many communities, I say that it would make no difference as we will continue to serve our area.

John R. Westwood
CFO
State Bank of Southern Utah
John R. Westwood, CFO