FDIC Federal Register Citations

Re: Community Reinvestment RIN number 3064-AC50

Dear Sirs:

These comments are in reference to the proposed rule on amending the CRA threshold up to $1 billion for "large bank" status. We are in favor of raising the threshold to $1 billion. The current requirements of being a "large bank" are such that it is very difficult to obtain the required objectives at our size and in our rural area. The reporting requirements are time-consuming and expensive. Investments are hard to find, and when you do, competition from very large banks is difficult to meet or overcome.

As a community bank, with two very rural assessment areas, we see the bank's assets_ being used in a much more effective fashion by being involved with those community programs and issues that are actually a part of a rural area. We do not see many of the issues that must be addressed in an urban area. We are actively involved in our communities, and will continue to be. Why not make "community investment" mean that a bank actually reaches out to the needs of the rural areas in a way that is beneficial to that area? Our customers and communities are more concerned about having better schools, adequate medical facilities, more doctors, and new industry coming to town.

We are determined to continually reinvest in our communities. Most of our population is low to moderate income, and we actively seek loans and provide services that we feel meet the needs. Help us to help our areas by raising the threshold so that we may use our resources in a more productive manner, and re-define "community development" to include those needs applicable to our rural area.

Sincerely,

Mary Wethington
Compliance Officer
HOME FEDERAL BANK