From: McKay, Cathy [mailto:CMcKay@palosbank.com]
Sent: Monday, August 16, 2004 11:25 AM
To: Comments
Subject: RIN 3064-XXXX
I am supportive of raising the small bank reporting asset size for
CRA from $250M to $1B. There are a significant number of community banks
with asset sizes between $250M or $500M and $1B who are currently
subjected to playing on the same field as their big brothers. Community
banks are, by their nature and definition, dedicated to the communities
in which they are located and whom they serve. Community bank resources
cannot be equated with the resources available at the larger
institutions (i.e. > $1B). The regulations as they stand, have not been
fairly recognizing the divergence in the nature of these two types of
facilities. Raising the limit for small bank reporting to $500M does not
go far enough--we need the more appropriate distinction of small bank
versus large bank set at $1B. Thank you for your consideration.