Federal Deposit
Insurance Corporation

Western State Bank

October 13, 2004

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

Concerning: RIN #3064-AC50

Mr. Feldman,

Iwould like to comment in favor of the FDIC's proposal to raise the Community Reinvestment Act (CRA) small bank threshold from $250 million to $1 billion. Western State Bank is a $300 million bank doing business in four small western Kansas towns and one moderate sized western Kansas town. We do almost all of our deposit business throughout these communities and make most of our loans in the same five counties. As a normal part of doing business and trying to grow, we make specific efforts to open deposit accounts with anyone in our five counties. If you have $100 you can open a free checking account with us. Our customers come from every income group. We, and every other bank in our communities, are doing business with moderate and low income families as a normal part of our operations.

This was the first year for us to provide the information required of banks larger than $250 million. We have spent much time and experienced some frustration trying to provide the information required by the present regulations. We have been able, after spending a fair amount of time, to identify our agricultural and business loans with gross income under $1 million.

We have spent much more time trying to get those addresses to fit within the census tracts. Many of our farm customers do not have physical addresses, they use rural route box numbers. Part of the problem is the geographical locations in a census tract are changed from time to time by some regulator, probably your associates. After our data processing officer and compliance officer spent about two weeks trying to get our addresses to fit into your census tracts, we hired a consultant and paid him $2,500 to present the information in a format acceptable to your corporation.

We support the FDIC's efforts to raise the CRA small bank threshold significantly because we already do business with all the folks in our communities and proving it to you takes a lot of time and money. That time can be better spent providing customer services and making loans.

Thanks for the opportunity to give your our thoughts.

Sincerely
Jeff Whitham, CEO