FDIC Federal Register Citations

September 15, 2004

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

re: Community Re-Investment
RIN No. 3064-AC50
Proposal to Expand Eligibility
For Streamlined CRA Exam

Dear Mr. Feldman:

I am in strong support of the FDIC proposal to increase the asset size to $1 Billion for the streamlined small bank CRA examination. Community Banks such as Blackhawk State Bank (asset size about $575,000,000.) must serve their communities if they are to prosper. We cannot and do not take deposits from our local market and make loans in California, Texas or wherever the rate of return is greater. Re-investing in our own Quad City Market is something we do every day as a matter of good business practice.

Those who want to lower the limits of exemption simply don't understand Community Banking. Also, they don't understand the costs and time burdens of excessive examination. They also don't understand how large banks are examined. Wells Fargo Bank and U.S. Bank have several facilities each in our market. Both of these banks have more deposits in our Quad City Market than does Blackhawk Bank. However, these local offices don't get on-site visits for evaluation when Wells Fargo or U.S. Bank is examined for compliance.

I support the concepts of Community Re-Investment Act, and I believe that we comply with the provisions. This proposal would not exempt us from CRA....we would still be fully obligated to comply with the Act, and we are committed to do that.

Very truly yours,

W. Gerard Huiskamp
President