Federal Deposit
Insurance Corporation

via e-mail

AMERIMARK BANK

February 25, 2004

Robert E. Feldman
Executive Secretary
Attention: Comments, Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429

Comments on FIL-15-2004 Proposed Amendments to the Community Reinvestment Act

Dear Mr. Feldman:

AmeriMark Bank is a community bank which has approximately $160 million in assets. The Bank primarily serves the communities surrounding its two full service branches and one drive-in and ATM convenience center in the western and southwestern suburbs of Chicago, IL. We are involved in our communities and believe that the current regulations for CRA for “small institutions” are appropriate.

We agree that the threshold for a “small institution” should be raised. We believe that the threshold for a “small institution” should be financial institutions with total assets less than $1 billion. We believe that the additional compliance costs for new personnel and outside contractors, data collection, and reporting costs are very significant and burdensome for institutions below $1 billion in assets. These smaller institutions are involved in their communities and provide the investment and credit for community development. The CRA regulations should reflect the recent consolidation of the industry. The industry is continuing to see a bar bell effect with mega banks on one end of the spectrum and smaller banks on the other side with the medium sized institutions merging or being bought by larger institutions.

The mega banks of CitiCorp, JP Morgan Chase/ Bank One, Bank America and Wells Fargo have far more resources and impact on community development than financial institutions with less than $1 billion in assets. Financial institutions with $1 billion in assets or more have many more branches and ability to serve entire metropolitan areas rather than specific communities in a metropolitan area. The current regulation ensures the “smaller institutions” are complying with CRA without placing undue burden on the institution. We would recommend that the threshold for “smaller institutions” be raised to financial institutions with assets less than $1 billion in assets.

Sincerely,