Federal Deposit
Insurance Corporation

September 20, 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 Sir or Madam:

I am Jeff Crawford of Wood & Huston Bank, located in Marshall, Missouri, a town of approximately 12,000 people. Wood & Huston Bank currently has assets of $330 million. I am writing in support of the FDIC’s proposal to raise the threshold for the small bank CRA examination to $1 billion without regard to the size of the bank’s holding company.

I made a comment a couple of years ago arguing that the $1 billion benchmark was much more accurate in defining what a large bank was. I was at a Missouri Banker’s Association conference recently and we broke up into “peer group” sessions to talk about different subjects. The group I was in was “large banks” which they defined as $250 million in assets and up. What was immediately apparent was the irrelevance in how multi-billion dollar and trillion dollar institutions approach compliance issues and how our bank and others closer to our size approach them. The big banks in the group all had compliance departments, CRA departments, audit departments, etc. whereas I am the compliance officer, CRA officer, internal auditor, etc. There were multiple people in the group that were from the same institution but the bank was so big and covered such a large geographical area that those people only saw each other at conferences and departmental regional meetings of their bank. The criteria for large banks fits those larger institutions but it is plain common sense to see that banks under $1 billion in assets are run nothing like those larger banks and should be assessed using the streamlined small bank criteria.

Wood & Huston Bank’s main branch is located in Saline County Missouri. The bank is locally owned and has been here for 130 years. Over those 130 years, long before there was a CRA, it has been the normal course of business to take deposits from our community and lend those funds back to our community. Once the Community Reinvestment Act came about there was really no change needed in our lending practices for us to be in compliance.

However, in 2001 we consolidated our bank with two other banks owned under the Wood & Huston Bank Corporation and we exceeded $250 million in assets. Now, lending back into the communities that we take deposits from is not enough though that is the original intent of the CRA. We must now follow extremely detailed reporting requirements, seek out investments in areas that there are slim to no investments available, offer services that absolutely no one has attended yet, and finally try to find community development loans in assessment areas that have no low to moderate income census tracts and is 90%+ farm land. We must do all of this with the same staff we had before.

I could write pages and pages of problems caused by the large bank criteria for us. It is simple enough to say we have always invested back into our community. Now it is more important to appear that we are in compliance than actually being in compliance.

I am very pleased with the proposal to move the large bank status up to $1 billion and greater. The addition of the community development criteria will put us back in some part to where we were before. The opportunity for us to have community development lending will remain very slim unless a much more liberal definition is provided for a community development loan.

Thank you for the opportunity to present my feelings on the proposal.

Sincerely,