FDIC Federal Register Citations

From: Dorothy Bushnell [mailto:dbushnell@csbbanking.net]
Sent: Monday, October 18, 2004 3:46 PM
To: Comments
Subject: RIN number3064-AC50

October 13, 2004

Robert E. Feldman, Executive Secretary
Attention: Comments/Legal #ESS
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429

Dear Mr. Feldman:

As you requested, I would like to comment on the proposed amendments to the
Community Reinvestment Act.

The proposed amendment to change the definition of a small institution to
mean an institution with total assets of up to $1 billion, would certainly
relieve our institution of a very burdensome task. Our institution has had
to deal with the increased regulatory burden of data collection and
reporting on its small business, small farm and community development loans.
These are community banks that make the majority of their loans inside their
assessment areas.

Also, under the large bank CRA examination process, the investment test is
difficult for a community bank to attain a satisfactory rating. With
regional and national banks competing for suitable investments in our
market, they have an unfair advantage due to their size. The larger banks
will spend whatever it takes to get those investments, making it harder for
the smaller institutions to get a satisfactory rating at exam time.

We are in favor of changing the definition of a small institution to one
with total assets of up to $1 billion without regard to the holding company
assets.

Thank you for considering this matter.

Sincerely,

Dorothy Bushnell
VP - Branch Manager