Robert E. Feldman, Executive Secretary
Attention: Comments, FDIC
550 17th Street, NW
Washington, DC 20429
Re: FIL-15-2004, Proposed Rules on CRA published in the Federal
Register on February 6, 2004
Dear Ladies and Gentlemen:
Citizens Bank of Southern Pennsylvania strongly supports the proposal
you have published in the Federal Register to change the criteria for a
"small bank" under the CRA. We do business in a smaller, more rural
community. The opportunities for qualified investments are few and far
between, unlike more metropolitan areas. Your examiners have explicitly
recognized this reality. This places us in the position of having to
look for investment opportunities outside of our direct assessment areas
and rely on the "broader statewide or regional area" allowance in the
regulation. This seems to be counter-intuitive to the whole purpose of
the CRA, to appropriately serve all of the segments of one's market.
By changing the definition of a small bank as you have proposed, we
will be able to concentrate on what we do best: lending. Further we will
no longer be distracted from what our business truly should be serving
our direct assessment area.
Thank you.
Sincerely,
John R. Rotz
President and CEO
Citizens Bank of Southern Pennsylvania
35 N. Carlisle St.
Greencastle, PA 17225-0400
