FDIC Federal Register Citations

First State Bank of East Detroit

From: Kim Schmidt [mailto:kschmidt@thefsb.com]
Sent: Monday, September 20, 2004 5:59 PM
To: Comments
Cc: pssmith@aba.com
Subject: RIN number 3064-AC50

Mr. Robert E. Feldman
Executive Secretary
Attention:Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th street NW
Washington, DC 20429
re: RIN Number 3064-AC50

Dear Mr. Feldman,

I am a Second Vice President of First State Bank of East Detroit, with several locations located in Macomb County.

We strongly support the FDIC's proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of the bank's holding company. We also support the addition of a community development criterion to the small bank examination for larger community banks, but believe that the FDIC should adopt its original $500 million threshold without a Community Development (CD) criterion. The new CD criterion should be applied only to banks greater tht $500 million up to $1 billion.

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 include rural residents.

I believe that the FDIC has proposed major improvement in the CRA regulations and I urge the FDIC to adopt its proposal.

Sincerely,

Kim Schmidt
Second Vice President