Federal Deposit
Insurance Corporation

Iowa Area Economic Development Group

October 29, 2004

Attn. Robert E. Feldman
Executive Secretary
Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, D.C. 20429

RE: RIN 3064-AC50

Dear Mr. Feldman:

As the head of the Iowa Area Economic Development Group located in West Des Moines Iowa, We are pleased to comment in support of the proposal issued by the FDIC that would amend the definition of a small institution to be a bank that is under $1 billion in assets.

We believe that this change will provide much needed regulatory burden relief for community bankers with whom our organization does a great deal of work. The regulatory burden that government is placing on our businesses is becoming overwhelming and affecting what their real mission is - the change you are considering is one example of regulatory burden relief that will really make a difference. We would much rather see community banks make use of their limited resources to serve the community than to collect and maintain data and documents to show examiners in Washington D.C. We guarantee the market place does a very good job of rewarding those banks that are doing the job and likewise they effectively penalize those banks that are not.

We work with all kinds of financial intermediaries our knowledge banks are the only ones that are required to comply with this over burdensome law. We can tell you that community banks were doing a great job of serving their community prior to the Community Reinvestment Act and they continue to do a great job after the rules went into effect - this additional burden has done little if anything to enhance community reinvestment and again creates more work then there are resources.

We strongly urge you to amend the definition of a small bank for CRA purposes to be an institution with less than $1 billion in assets, regardless of whether the bank is part of a holding company. This is a good proposal and is the right thing to do.

Thank you for considering our views.
Rand M. Fisher
President