Federal Deposit
Insurance Corporation

PiBank

October 7, 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,

I am writing today in support of the FDIC's proposal to increase the threshold for small bank streamline examinations. We are a relatively new (three years old) community bank in Seattle. We serve a Korean-American population of about 125,000 in the greater Seattle/Tacoma area with our Korean-speaking staff. We have two branches and $100 million of assets. We have just formed a Bank Holding Company to facilitate our services outreach.

The amount of attention even a bank as small as ours must pay to CRA compliance is considerable. Translating copies of our print and radio advertising, continually updating our lending footprint with the board of directors, training staff, paying for outside compliance audits and other necessary actions consumes at least 80 hours of staff time annually and in 2004 had a direct out-of-pocket cost of $12,000.

Our small lending limit puts a cap on the number of CRA-qualifying projects we can even consider. We feel that we, and our community, would be much better served if we could freely substitute certain services for discrete lending and investments to meet our obligation to the larger society and satisfy the intent of Congress, as we understand it.

Thank you for letting us comment on this proposed rule change.

Sincerely
Woosing (Edward) Park, President
Chief Executive Officer