FDIC Federal Register Citations

September 14, 2004

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

Re: Community Reinvestment, RIN number 3064-AC50;
Proposal to Expand Eligibility for the Streamlined CRA Exam

Dear Mr. Feldman:

Bank of Commerce is a $250 million bank located in a rural community whose average median income as of the 2000 census is $32,679. Reinvesting in our communities is something we do as every opportunity arises. The primary market in our area is agricultural loans and agriculture related businesses.

To increase the "Small Bank" definition to $1 billion regardless of holding company affiliation and expand the definition of "community development" to encompass a broader range of activities in rural areas would have a tremendous positive impact on Bank of Commerce and other rural banks and the communities served. This would enable Bank of Commerce to better focus resources on community based lending activities and the development of more selective investments and services in the community.

Expanding the definition of "community development" to include activities that benefit rural residents in addition to low-and moderate income will help community banks attend to the special needs of our communities to improve the quality of life. Bank of Commerce is frequently called upon to fund and support local organizations that help create needed or better paying jobs. These organizations often provide an outreach program that requires special financial services or education.

Under the current CRA regulation, the investment requirements are difficult to meet for banks in "rural" communities. Investment opportunities are not an every day or annual occurrence. To comply with the current regulation, Bank of Commerce must invest mostly in regional and state bond issues and the like. While these investments benefit other areas, valuable resources are taken out of our communities. Those dollars, time and effort would greatly benefit our communities by providing other services such as financial education, participation in economic/community development projects and other activities that impact low-and moderate income and rural residents.

Your proposed changes are needed to help provide meaningful data for analysis of each bank's CRA performance and simultaneously eliminating outdated and ineffective requirements of the current regulation.

Sincerely,
J. W. Landry, Attorney
Chairman of the Board
Bank of Commerce and Trust Company
Crowley, LA