Federal Deposit
Insurance Corporation

From: Vicki Turnquist [mailto:VickiT@pbmn.com]
Sent: Wednesday, October 13, 2004 4:26 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

My comments related to the proposed rule changes are the following:

I support the revision to increase the small bank threshold from $250 million to $1 billion.

I also support adding the community development criterion and would support it for even smaller banks than $250 million. As a $120 million bank in a metropolitan market there is strong competition for the low to moderate income loans that are available and a small organization sometimes cannot compete with the larger banks. We do service work and charitable contributions to help fulfill our CRA goals. More flexibility in this arena would be helpful.

Vicki L. Turnquist
Private Bank Minnesota
Direct: (612) 305-4221
Fax: (612) 436-3570