Federal Deposit
Insurance Corporation

Amalgamated Bank

October 14, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW Washington, DC 20429

RE: RIN number 3064-AC50

Dear Mr. Feldman:

At Amalgamated Bank we strongly support the FDIC's proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of the bank's holding company. By adopting this proposal community banks would still be required to help meet the credit needs of their entire communities and continue to be so evaluated by their regulator, but it would greatly relieve the regulatory burden imposed on small banks under the current regulation, which requires them to meet the standards imposed on the nation's largest banks.

Also, we encourage the addition of a community development criterion to the small bank examination, and we have no objection to applying this to banks with assets greater than $250 million and up to $1 billion. In addition we strongly oppose making the community development criterion a separate test from the bank's overall CRA evaluation, since such differentiation creates the impression that community development lending is different from the provision of credit to the entire community. The current small bank test considers an institution's overall lending in its community, and the addition of a category of community development lending (and services to aid lending and investments as a substitute for lending) fits well within the concept of serving the whole community. A separate test would create an additional community development obligation and regulatory burden, eroding the intent of the streamlined exam.

Finally, we support the FDIC's proposal to change the definition of community development from only focusing on low- and moderate-income residents to including individuals and activities in rural areas.

Amalgamated Bank urges the FDIC to adopt the proposal.

Sincerely,
Gabriel P. Caprio
President & CEO