From: David Murphy [mailto:dmurphy@fsbcarthage.com]
Sent: Thursday, September 16, 2004 1:23 PM
To: Comments
Cc: psmith@aba.com
Subject: Increase of CRA threshold to $1 Billion
We are strongly in favor of the FDIC's proposal to increase the
Community Reinvestment Act threshold for small banks to $1 billion
without regard to the size of a bank's holding company. We will continue
to help to meet the credit needs of the entire community and will
continue to be so evaluated by our regulators, but the regulatory
burden that the current legislation imposes on a bank of our size
is incredible.
We support the addition of a community development criterion to the
small bank examination for larger community banks, but we believe
the new community development
criterion should be applied only to banks greater than $500 million up to $1
billion. We strongly oppose making the community development criterion a separate
test from the bank's overall CRA evaluation. Finally, we strongly support the
FDIC's proposal to change the definition of "community development" from
only focusing on low- and moderate-income area residents to including rural
residents.
Thank you for your consideration of these proposals and our thoughts.
David B. Murphy
Vice President and Investment Officer
First State Bank & Trust Company
Carthage, Texas
