FDIC Federal Register Citations

Tompkins Trust Company

October 5, 2004

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

Re: RIN Number 3064-AC50

The Tompkins Trust Company endorses the FDIC's efforts to reduce regulatory burden and strongly supports the FDIC proposal to increase the threshold for the streamlined small-bank CRA examination to $1 billion without regard to the size of the bank's holding company.

This proposal recognizes that community banks meet community needs through reinvestment in their community. Smaller institutions would be relieved from burdensome regulatory requirements. The application of the same CRA requirements to small community banks as one imposed on the nation's largest financial institutions does not recognize marketplace reality for financial institutions.

Inclusion of the community development criterion to the small bank examination for larger community banks is a positive test and more appropriate than the large bank investment test. We would urge; however, that the FDIC should adopt its original $500 million threshold without the community development criterion. This new criterion should be applied only to banks greater than $500 million up to $1 billion.

Under the current CRA exam for large banks, the definition of "qualified investments" is too limited and it is extremely difficult for small banks to find appropriate CRA qualified investments in their communities.

Community banks are under increasing pressure to meet additional regulatory and reporting burdens. Survival of community banks as financial service providers becomes more difficult. It is important for regulators to recognize and preserve the unique role and mission of community banks in the financial services marketplace.

We thank you for recognizing that "one size does not fit all" when it comes to CRA, and we urge you to adopt the pending regulation.

Sincerely,
Edward F. Dawson
Vice President