STEUBEN TRUST COMPANY
February 27, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments, Federal Deposit Insurance Corporation
550 17th Street, NW.
Washington, DC 20429
Dear Mr. Feldman,
In response to FIL-15-2004, Community Reinvestment Act, dated
February 6, 2004, I have the following comments:
As a small independent bank located in southwestern New York State,
we feel the current CRA Act provides an unnecessary burden and expense
for not only our bank, but for all small community banks. We have
offices in two counties, neither of which are in a MSA. The fact that we
are able to provide the latest in products and services to our
customers, plus having a satisfactory loan to deposit ratio, should
demonstrate that we are meeting the credit needs of our communities. By
the sheer nature and location of small community banks, we serve the
broad needs of our whole rural community.
Recently we became a large bank as our assets total reached $250
million. There is no change in the bank's operations, other than stiffer
competition from larger institutions offering products and services that
we must compete against. In a large bank examination, we now are forced
to be judged in a lending and service test (which we welcome), but an
investment test as well. We found it has been difficult to compete for
investment opportunities, particularly against much larger institutions.
I welcome the increase in the large bank threshold, but feel it has
not been increased enough. We would like to see total assets size be
increased to $1 Billion.
I thank you for the opportunity to comment.
Sincerely,
STEUBEN TRUST COMPANY
Brenda L. Copeland
President and CEO
