From: Timothy S. Avery
Sent: Tuesday, August 17, 2004 3:07 PM
To: Comments
Subject: RIN number 3064-XXXX
To Whom it May Concern,
Please accept this correspondence as Scott Valley Bank's comment
of support for the proposed revisions to 12 CFR 345, implementing
the Community Reinvestment Act (CRA) that would: a) change the
definition of "small bank" to raise the asset size threshold
to $1 billion regardless of holding company affiliation; b) add
a community development activity criterion to the streamlined evaluation
method for small banks with assets greater than $250 million and
up to $1 billion; and c) expand the definition of "community
development" to encompass a broader range of activities in
rural areas.
Our support of this proposal is predicated on the belief that the
recommendations for change to consider involvement in rural communities
will recognize the many and varied positive influences small banks
have on the communities they serve. This represents a very "real" approach
to measurement of Community Reinvestment and the essence of its
original intent.
The focus should be on pragmatic review of activities which support
not only the lending activities in Low and Moderate income service
areas and specific targeted investment and service contributions,
but also services that provide benefit to entire communities, when
significant percentages of the general population of a community
meet similar criteria.
Recognition of the fact that banks under $1Billion in assets are
truly "small" banks is long overdue. Please accept this
bank's support of the current FDIC proposal.
