From: Kim Schmidt [mailto:kschmidt@thefsb.com]
Sent: Monday, September 20, 2004 5:59 PM
To: Comments
Cc: pssmith@aba.com
Subject: RIN number 3064-AC50
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 a Second Vice President of First State Bank of East Detroit, with several
locations located in Macomb County.
We strongly support 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. We also support the addition of a community development
criterion to the small bank examination for larger community banks, but believe
that the FDIC should adopt its original $500 million threshold without a Community
Development (CD) criterion. The new CD criterion should be applied only to
banks greater tht $500 million up to $1 billion.
We strongly oppose making the CD criterion a separate test from the bank's
overall CRA evaluation.
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 include rural residents.
I believe that the FDIC has proposed major improvement in the CRA regulations
and I urge the FDIC to adopt its proposal.
