FDIC Federal Register Citations

First Independent Bank of Nevada

October 19, 2004

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 Ladies and Gentlemen:

Below are a few items I would like to address on behalf of my community bank:

• 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 will still be required to help meet the credit needs of our entire community and would continue to be evaluated by our regulator.

• We strongly oppose making the CD criterion a separate test from the bank’s overall CRA evaluation. Such differentiation creates the impression that CD lending is different from the provision of credit to the entire community. The current small bank test considers the institution’s overall lending in its community. The addition of a category of CD lending (and services to aid lending and investments as a substitute for lending) fits well within the concept of serving the whole community. A separate test would create an additional CD obligation and regulatory burden, eroding the intent of the streamlined exam.

• 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 including rural residents. This change will go a long way toward eliminating the current distortions in the regulations that result in a small rural bank being told to invest in regional affordable housing bonds for an urban area not in the bank’s community.

Thank you for your consideration.

Sincerely,

Mike Hix
Vice President/Branch Administrator
First Independent Bank of Nevada
5335 Kietzke Lane
Reno NV