From: Kirk Buxton
Sent: Tuesday, February 10, 2004 12:17 PM
To: Comments
Subject: CRA proposed rulemaking
We are a $340 million
bank which became a “large” bank
for CRA purposes on 1/1/04. Under the proposed rules, we will again
qualify to be examined as a “small” bank when the rules
take effect. If the new rules take effect on August 15, for example,
we will have been a large bank for the first part of the year 2004
and a small bank for the remainder of the year and at least for several
more years thereafter. We believe that if we’re examined by
the FDIC after the rules become effective, it would be appropriate
to be examined as a small bank and we would like the final rule to
clarify this. In the meantime, we continue to work hard in all three
areas—lending, service and investment—and would continue
to work in these areas even as a small bank in an attempt to achieve
an “outstanding” rating. Thank you. Thomas Buxton
