FDIC Federal Register Citations

CITIZENS BANK OF SOUTHERN PENNSYLVANIA

February 27, 2004

Robert E. Feldman, Executive Secretary
Attention: Comments, FDIC
550 17th Street, NW
Washington, DC 20429

Re: FIL-15-2004, Proposed Rules on CRA published in the Federal Register on February 6, 2004

Dear Ladies and Gentlemen:

Citizens Bank of Southern Pennsylvania strongly supports the proposal you have published in the Federal Register to change the criteria for a "small bank" under the CRA. We do business in a smaller, more rural community. The opportunities for qualified investments are few and far between, unlike more metropolitan areas. Your examiners have explicitly recognized this reality. This places us in the position of having to look for investment opportunities outside of our direct assessment areas and rely on the "broader statewide or regional area" allowance in the regulation. This seems to be counter-intuitive to the whole purpose of the CRA, to appropriately serve all of the segments of one's market.

By changing the definition of a small bank as you have proposed, we will be able to concentrate on what we do best: lending. Further we will no longer be distracted from what our business truly should be serving our direct assessment area.

Thank you.

Sincerely,

John R. Rotz
President and CEO
Citizens Bank of Southern Pennsylvania
35 N. Carlisle St.
Greencastle, PA  17225-0400