Federal Deposit
Insurance Corporation

October 6, 2004

Robert E. Feldman
Executive Secretary
Attention: Comments Legal ISS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429-9990

Re: RIN 3064-AC50

Dear Mr. Feldman:

We are a regional CDFI small business lender and technical assistance provider, serving a fourteen county area of rural upstate New York. Throughout our twenty-year history, we have relied on the banking community to support our efforts through the provision of community investments, matching funds, loan loss reserve and technical assistance funding. The banks have been willing to do this, in part, because it meets their CRA goals.

In light of that, I would ask that you please do not change the definition of a small bank from $250 million to $1 billion. In our rural region, this may well exempt all of the banks serving some of the smallest rural communities. Also, banks should not receive CRA credit for activities that do not benefit low and moderate-income people and places. Most of our communities are low income, and have historically experienced high unemployment and poverty. This is where we as a CDFI spend our funds to create development. We need the banks' help in doing this, both their support to us and their lending into those communities. These changes would create an additional hardship for rural communities by reducing rural lending, investments and services.

We need rule changes that further encourage banks to increase their investment into those communities that most need assistance.

Respectfully,

Wayne R. Glass
Vice President, Community Initiatives
Adirondack Economic Development Corporation
Saranac Lake, NY