From: Rhonda Ferrara [mailto:rferrara@skowsavings.com]
Sent: Thursday, September 16, 2004 8:55 AM
To: Comments
Cc: 'psmith@aba.com.'
Subject: CRA Proposal
To Whom This May Concern,
Skowhegan Savings Bank strongly support's 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. This
would greatly relieve the regulatory burden imposed on small banks under
the current regulation, which are required to meet the standards imposed
on the nation's largest $1 trillion banks. Skowhegan Savings Bank would
still be required to help meet the credit needs of their entire
communities and would continue to be so evaluated by their regulator.
Additionally, Skowhegan Savings Bank strongly supports 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. This change will go a long way toward eliminating the current
distortions in the regulations that result in a small rural bank being
told to invest in regional affordable housing bonds for an urban area
not in the bank's community.
