Federal Deposit
Insurance Corporation

From: Bill Radosevich [mailto:Radosevich@minn.net]
Sent: Sunday, October 17, 2004 12:12 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Hi,

I am opposed to a change in the definition of small banks which would ignore the size of it's holding company. With continuing consolidation of the banking industry, the option of structuring bank acquisitions in such a way as to define all banks owned by increasingly large holding companies seems inevitable.

In the Federal Register, (August 20, 2004 (Volume 69, Number 161)]) it was stated that "Industry commenters stated, in response, that they were unaware of any institutions that choose their form of corporate organization in order to minimize their CRA compliance burden."

The opportunity to reduce community reinvestment created by the change in small bank definition will likely be taken up by large holding companies in an effort to reduce costs and increase profits.

The resulting loss of services to underserved communities seems inevitable. The CRA was intended to ensure that large banks provide equal access to financial services, and prevent 'cherry-picking" of profitable services while avoiding higher risk investments in the communities they serve

Bill Radosevich
3415 Pillsbury Ave S
Minneapolis, MN 55408