FDIC Federal Register Citations

Laurel Savings Bank

September 16, 2004

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

Re: Community Reinvestment RIN number 3064-AC50

Dear Mr. Feldman:

As a community banker, I am pleased to comment in support of the August 20, 2004 proposal issued by the FDIC amending the definition of a small institution to be a bank that is under $1 billion in assets. We believe that this change, if adopted, will provide much needed regulatory burden relief for Laurel Saving Bank and other community banks. Having just recently become subject to the large bank CRA requirements, we are simply amazed at the additional requirements we've been subjected to in order to comply with these requirements. To subject a $300 million community bank to the same CRA requirements as a multi-billion national bank defies comprehension. We would certainly prefer to use the limited resources available to our bank to serve the financial needs of the communities we serve as opposed to collecting and maintaining documentation to prove to examiners that we are meeting the needs of our communities.

Being a community bank, by its very nature, requires that we meet the financial needs of our communities. If the communities we serve don't survive and prosper, neither would our financial institution.

Laurel Savings Bank is a $300 million institution with eight (8) branches and seventy (70) employees. We deal primarily in residential mortgage loans, with additional investments in commercial real estate and consumer loans.

We surely do not need complicated examination processes, procedures and scrutiny to show that we are serving the financial needs of our communities.

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, or possibly larger, regardless of whether the bank is a part of a holding company. This proposal deals with the correct approach to reforming CRA regulations and is simply the right thing to do.

Thank you for considering our views.

Sincerely
Edwin R. Maus
President and Chief Executive Officer