FDIC Federal Register Citations

West Alabama Bank & Trust

October 11, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Re: Community Reinvestment Act Proposal — RIN number 3064-AC50

Dear Mr. Feldman:

Thank you for the opportunity to comment on the proposed changes to the Community Reinvestment Act.

A community bank's main function is in meeting the credit needs and deposit needs of the citizen's of its communities which includes, but is not limited to, just low and moderate income individuals. Community banks located in rural areas, also, do not have the same advantages as banks located in urban areas.

We fully support changing the definition of "small bank" by raising the asset size to $1 billion regardless of holding company affiliation. We also fully support expanding the definition of "community development" to include a broader range of activities in rural areas that would cover the types of activities that are actually available and needed in rural areas.

A bank's community reinvestment activities should be judged by the opportunities within the institution's community and compared with the institution's peers, rather than being compared to a national average that includes areas with significantly different CRA opportunities and available activities.

Respectfully yours,
Mrs. Vicki H. Morton
Compliance Officer