FDIC Federal Register Citations

From: Sharon Garb [mailto:SharonG@horiconbank.com]
Sent: Wednesday, October 20, 2004 12:42 PM
To: Comments
Subject: RIN number 3064-AC50

Good Morning,

I would like to take this opportunity to comment on the proposed revisions to 12 CFR part 345 implementing the Community Reinvestment Act.

Horicon Bank is one of the many financial institutions to be affected by the outcome of these revisions; our assets are $340 million. We are a community bank located primarily in a rural area, and we struggle to identify CRA qualified investments because there are few community development corporations and few low to moderate income census tracts. We currently have only two moderate census tracts in our assessment area and no low income tracts. By expanding the definition of community development to include a broader range of activities in rural areas would have a positive affect on our Bank.

The CRA rules should be revised to increase the small bank threshold from $250 million to $1 billion. In addition, for banks with assets greater than $250 and up to $1 billion, the proposal adds a new community development criterion to the small bank performance standards that would provide us with flexibility among community-based lending, investment and service activities. Finally, the proposal expands the definition of community development to encompass a broader range of activities in rural areas.

If the proposed revisions are adopted, it would help Horicon Bank to remain competitive while continuing to provide great support for all areas of the communities we serve.

Thank you for your time.

Sharon K Garb, Vice President & CRA Officer
Horicon Bank
326 E Lake Street
Horicon, WI 53032