FDIC Federal Register Citations

Bank of Odessa

13 October 2004

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

Dear Sir or Madam:

I am the Executive Vice President of the Bank of Odessa, which is located in Odessa, Missouri, a small town with fewer than 5,000 residents. I am writing to express my strong support for the FDIC's proposal to raise the "large bank" threshold to $1 billion without regard to the size of the bank's holding company. We also support the addition of a community development criterion to the small bank examination for larger community banks. However, we believe that the FDIC should adopt its $500 million threshold without a community development criterion. Instead, the community; development criterion should be applied only to banks with assets greater than $500 million up.to.$1 billion.

The Bank of Odessa is a community-oriented bank with assets ranging from $275 million to $290 million, and we are highly visible in our community. We support community development by banks, but find ourselves overwhelmed by our recent transition from a "small bank" to a "large bank". We are staffed as a small community bank, and participating in the "large bank" program is proving very burdensome. Everyone at the Bank of Odessa has multiple responsibilities, and the CRA standard for "large bank" doesn't appear to take into consideration institutions staffed as ours is.

The trend seems to be if or big banks to become bigger, and the decreasing number of banks of our size appears to be leading regulators to direct their efforts to suit larger banks. It seems clear that evaluating a bank of our size in the same fashion as a $1 trillion bank is unreasonable. Additionally, it seems inappropriate to assess the Bank of Odessa in the same fashion as a bank located in a major metropolitan. area. Urban centers offer more opportunities for a bank to meet the community development criterion than do rural centers, and the Bank of Odessa's business is primarily located in a rural area that provides few opportunities for meaningful community development efforts. This makes it difficult to meaningfully meet the community development requirement under the large bank CRA standard.

In,conclusion, I urge you to adopt the $1 billion dollar standard for "large bank" and to apply the ommunity development criterion in the way outlined above. I would be happy to discuss these issues
further with you if you have any questions.

Sincerely
Daniel R. Cobb
Executive Vice President