FDIC Board of Directors
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC
Re: "Small Bank" CRA Threshold
Gentlemen:
This is in response
to the press release of August 16th, 2004 titled FDIC Seeks Additional
Comments on "Small-Bank" CRA Threshold.
It is the firm belief of this Bank that the proposal outlined in
the press release would provide the "Small-Bank" with a
far greater opportunity to better serve community development based
on the needs of the community or communities it serves.
The proposal would also lessen the regulatory burden that often
forces us to concentrate our efforts in areas that may not be the
most advantageous to the community. As we look at the various communities
we serve, we find diverse needs. By opening us up to greater opportunities
and less regulatory requirements,
you will only enhance our ability to be of greater service in these
communities and provide us with the advantage of being able to have
a more focused approach to our community development efforts. Additionally,
the revision of the rule will also allow us to reevaluate this focus
as needs change.
Thank you this opportunity to express our comments on the proposed
rule.