FDIC Federal Register Citations

February 27, 2004

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

Dear Mr. Feldman,

In response to FIL-15-2004, Community Reinvestment Act, dated February 6, 2004, I have the following comments:

As a small independent bank located in southwestern New York State, we feel the current CRA Act provides an unnecessary burden and expense for not only our bank, but for all small community banks. We have offices in two counties, neither of which are in a MSA. The fact that we are able to provide the latest in products and services to our customers, plus having a satisfactory loan to deposit ratio, should demonstrate that we are meeting the credit needs of our communities. By the sheer nature and location of small community banks, we serve the broad needs of our whole rural community.

Recently we became a large bank as our assets total reached $250 million. There is no change in the bank's operations, other than stiffer competition from larger institutions offering products and services that we must compete against. In a large bank examination, we now are forced to be judged in a lending and service test (which we welcome), but an investment test as well. We found it has been difficult to compete for investment opportunities, particularly against much larger institutions.

I welcome the increase in the large bank threshold, but feel it has not been increased enough. We would like to see total assets size be increased to $1 Billion.

I thank you for the opportunity to comment.

Sincerely,

STEUBEN TRUST COMPANY
Brenda L. Copeland
President and CEO