FDIC Federal Register Citations

Union Bank Co

September 8, 2004

Scott M. Polakoff
Regional Director
Federal Deposit Insurance Corporation
500 West Monroe Street
Suite 3500
Chicago, IL 60661

Dear Mr. Polakoff

We appreciate the FDIC issuing a new proposal to solicit additional comments on the impact of changing the definition of a small bank for purposes of CRA to include those with total assets of up to $1billion, regardless of holding company affiliation.

The UNION BANK strongly supports your proposal to increase the size limit for community financial institutions eligible for the small bank streamlined Community Reinvestment Act Examination from $ 250 million to $1 billion. We also support establishing a community development test which would permit more choice for our financial institution to be evaluated based upon our community development lending, qualified investments or community development services, as opposed to all three. This proposal would also help our financial institution to better compete with multibillion-dollar financial institutions for qualified investments.

The FDIC proposal would replicate the recently finalized OTS rule, which raises the limit to $1 billion, effective October 1, 2004.

The proposed changes will not undermine the intended purpose of CRA and would ease the paperwork and examination burden on my financial institution.

Sincerely
Scott C. Lehman