FDIC Federal Register Citations

September 9, 2004

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

Re: FDIC's proposed rule regarding CRA

Dear Sir or Madam,

Thank you for allowing our bank to comment on your proposal to increase the threshold of a "small bank" from $250,000,000 to $1 billion.

The small bank CRA examination process was an excellent innovation. As a community banker, I applaud the FDIC for recognizing that it is time to expand this critical burden reduction benefit to our size bank. Our bank recently surpassed the $250,000,000 threshold and became subject to the "large bank" examination process.

When a bank must comply with the requirements of the "large. bank" examination, the process, the costs an burdens increase dramatically. And the limited resources devoted to CRA compliance are resources not available for meeting the credit demands of the community. The mission of a locally-owned community bank depends on how well it serves its community, not increased expenses in software, personnel costs and the difficult search to meet the Investment Test of the "large bank" evaluation.

Our bank is located in a rural, non-MSA area and has been in business for over one hundred years. The fact that we have been around for that time should indicate that we are meeting the credit needs of our community.

In surnmary, I believe that increasing the asset-size of banks eligible for the small bank strearnlined process is an important first step to reducing regulatory burden.

Sincerely,

James M. Locker
Vice President, Compliance, BSA, CRA Officer
Steuben Trust Company
Hornell, NY