FDIC Federal Register Citations

SSBBank

From: Balstout@aol.com [mailto:Balstout@aol.com]
Sent: Monday, September 20, 2004 10:01 AM
To: Comments
Cc: psmith@aba.com
Subject: RIN No. 3064-AC50

Dear Sir or Madam:

I am a Vice President of SSBBank located in the village of Stockbridge, Michigan. We are an $80 Million Bank with two branches. One in the Village of Gregory and one in the City of Eaton Rapids. We serve three rural communities in Michigan and presently are subjected to large bank CRA exams. I am writing to strongly support the FDIC's proposal to raise the threshold for the streamlined small bank CRA examination to $1 Billion. This would greatly relieve the regulatory burden imposed on us and the other small community banks.

We support the addition of a community development criterion to the small bank examination for larger community banks, but we believe that the FDIC should adopt its original $500 million threshold without a Community Development criterion.

We strongly oppose making the CD criterion a separate test from the bank's overall CRA evaluation.

We strongly support the FDIC's proposal to change the definition of "community development" from only focusing on low and moderate income area residents to including rural residents.

Thank you for your consideration in this matter.

Sincerely,

Al Stout - Vice President