Federal Deposit
Insurance Corporation

Midtown Financial Center
3111 C Street • P.O. Box 241489
Anchorage, Alaska 99524-1489

October 11, 2004

Robert E. Feldman
Executive Secretary
Attention: Comment/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW.
Washington, DC 20429
Re: RIN # 3064-AC50

Subject: Proposed Revisions to the Community Reinvestment Act Regulations

Dear Mr. Feldman,

Currently I am the CTO and Manager of Information Systems here at Northrim Bank, located in Anchorage AK. Northrim is a commercial bank here in the State at $739 million in assets.

I wish to address my support for the FDIC’s proposal to change the definition of a “small bank” by raising the large bank asset size to $1 billion, regardless of the size of a bank’s holding company.

As Northrim’s management and provider of IT services and infrastructure I am intensely aware of the ever-increasing regulatory burden on small banks like Northrim. As Northrim has moved from the small bank designation to the “large bank” it required additional resources for CRA loan data capture and reporting, both in manpower support, budget dollars, and IT related services. Northrim is also faced with additional regulatory burden presently with the Sarbanes-Oxley legislation, and the on going Gramm-Leach-Bliley Act. As a small IT shop, these additional burdens are often disproportional when compared to our traditional competitors in the market. Much of the regulatory environment has an economy of scale for larger financial institutions, but for a smaller bank in a geographical area as Alaska, these hard costs and time commitments can truly become a burden.

Thank you for this opportunity to voice my concern from a strong community bank perspective.

Sincerely,

Rich Jerger
Vice President
Northrim Bank
Northrim BanCorp Inc.

Cc: The Honorable Alan Greenspan Chairman
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551