FDIC Federal Register Citations

Business 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

Dear Mr. Feldman:

It is 7:45 P.M. on Tuesday, October 5, 2004 and drawing near to the end of a fairly typical day. Our Bank has grown to average assets of almost $160 million, a feat that our Board and Management take great pride in. We strive to service the needs of small business) and the consumers who own, operate and work at those small businesses. Because of our size, we really can't service anybody but these clients. Seems peculiar to me that I would even attempt to try and bank clients out of our community or beyond our means and expertise. My experience is that most banks and bankers that do, don't work out too well in a community institution like ours.

The purpose of this letter is to voice my support for raising the CRA exam threshold. I'm sure there are a variety of arguments as to why the "Streamlined CRA" exam threshold should be raised from $250 million to $1 billion, probably very valid and based on sound judgment and empirical evidence. When considering the decision, I would ask that you consider what's happened to our industry in the past few years that's caused many small institutions to say "I've had enough." Plainly spoken, I think it's time the small businessman, who just happens to be a banker, gets a break. Surely, if community bankers are not fulfilling their obligations to their community and customers, there are better ways to deal with the malingers than punishing the innocent.

Thanks for taking the time to read my epistle.

Sincerely
Harold C. Rauner
President

PS. By the way, could you work on getting us a tax break like the "not for profit" credit unions have?