BLACKHAWK STATE BANK

March 2, 2004

Robert E. Feldman
Executive Secretary
FDIC
550 17th Street Northwest
Washington DC 20429

RE: Proposed Amendments to CRA Regulations

Dear Mr. Feldman:

I have two comments:

First, I believe that the definition of "Small Institution" should be changed to less than $1 billion.

Second, I totally agree with your effort to address abusive lending practices. A pattern of extending secured loans based on foreclosure value where the borrower could not be expected to repay is despicable. Further, I would expand the definition to include those Holding Company's who have subsidiaries who offer "Pay Day" loans. These loans often have APR's of 300% to 500% and should be considered in the same realm as sub-par real estate financing.

Very truly yours,
 

W. Gerard Huiskamp
President
Blackhawk State Bank
Milan, IL  61264