From: Cynthia Ledford [mailto:cledford@plantersfirst.com]
Sent: Monday, August 16, 2004 11:33 AM
To: Comments
Subject: 3064-xxxx

To Whom It May Concern:

In reviewing the proposed changes to CRA, I feel that this would be a positive change for small banks. Many banks through consolidation of assets, have move up into the large bank criteria, but the criteria for the large bank, as it is now, makes the Investment portion of the requirement difficult for banks our size ($300M) to meet. Many banks our size and like us, are located in rural communities, therefore limiting the opportunities we have to meet the Investment portion of the Lending, Investment and Service Test.

We received a CRA examination earlier this year and received a Satisfactory. This was our first exam as a Large Bank. Previously we had been receiving “Outstanding” but we were not able to meet the additional Community Development “Investment” criteria as a Large Bank. Again, the examiner agreed that this was not the fault of the bank due to the limited opportunities. She noted that we were very active in all community development services and often took the lead role in our communities but our qualified investments were at best, adequate and were documented on the Performance Test as “Low Satisfactory” for both the Investment and Service tests. Therefore, she recommended “Satisfactory” for our CRA Evaluation, which we are still pleased with given this was our first evaluation as a “Large Bank”.

I believe most banks that are in our position would welcome some relief from additional requirements that stem from consolidation of branches and not from the way our banks operate or provide financial services to all our designated communities. I do not feel that a change such as the ones being proposed would have any adverse action in the way banks are meeting the needs of low- and moderate-income individuals.

Sincerely,

Cynthia P. Ledford
Compliance Officer
PlantersFIRST, Cordele, Ga.