From: Tubbs, Al [mailto:altubbs@ohnward.com]
Sent: Thursday, September 16, 2004 11:52 AM
To: Comments
Subject: CRA proposal
This is to lend support to the proposal to increase the CRA threshold
for small banks to $1bil. on a bank by bank basis as opposed to H.C.
size. Our H.C. is over $500 mil., but our largest bank is $230 mil. CRA
regulations are imposed at a bank level not a H.C. level and in the
interest of regulatory relief it just makes sense that the threshold is
per bank and clearly set above a community bank size. Our community
banks are solely dependent on how well we take care of and support all
elements of our communities. There is no extended market, thus we focus
both the incorporated communities and the rural areas which are the
markets within our reach. Rural markets are often low and moderate
income so we support the change of definition os "community development"
from focusing only on low-moderate income to include rural areas. But we
don't need more paperwork at smaller bank levels to prove it. Thank you
for your consideration.
Sincerely, Alan R. Tubbs, CEO, Maquoketa State Bank and Ohnward
Bancshares, Inc., Maquoketa, Iowa
