From: Christine G. Davis [mailto:cdavis@bedford.net]
Sent: Wednesday, September 15, 2004 4:02 PM
To: Comments
Subject: RIN 3064-AC50
FROM: CHRISTINE G. DAVIS
TO: COMMENTS
SUBJECT: COMMUNITY REINVESTMENT - RIN 3064-AC50
WE ARE A PRIVATE NON-PROFIT COMMUNITY DEVELOPMENT CORPORATION SERVING
TWO
RURAL COUNTIES IN PENNSYLVANIA. WE HAVE JUST BEGUN TO DEVELOP CLOSE
PARTNERSHIPS WITH A COUPLE OF SMALL LOCAL BANKS. EACH OF THESE BANKS
FALL
BELOW THE PROPOSED THRESHHOLD UNDER THE NEW RULES. AS THE CRA CREDITS
ARE
THE CATALYST FOR THESE PARTNERSHIPS IT WOULD BE EXTREMELY DETRIMENTAL TO
OUR
RURAL COMMUNITIES SHOULD THE FDIC's PROPOSED CHANGE OCCUR.
WE STRONGLY OPPOSE THIS PRPOSAL CHANGE TO RAISE THE THRESHOLD
DEFINITION OF
SMALL BANKS, WHICH WOULD DECREASE OR MORE LIKELY TERMINATE COMMUNITY
REINVESTMENT BY SMALL LOCAL BANKS IN RURAL AREAS
