Subject: File No. S7-45-10
From: Anthony J. Worden
Vice President - Commercial Lending
Greenfield Co-operative Bank

February 18, 2011

To Whom It May Concern:

The proposal being discussed to require all banks to register with the SEC and be subjected to examination by them is unnecessary and would add further burden on community banks that have performed strongly during the recent crisis. Further my bank provides the same products and services to municipalities and other governmental entities that we do to any other commercial customer. As a state chartered mutual bank in Massachusetts all our customer deposits are fully insured with no risk to the municipalities (or any customer for that matter). It is patently unfair to add another layer of oversight on community centered banks such as Greenfield Cooperative Bank that have been operated wisely and prudently for many decades and that have not contributed to the crisis that is triggering these proposals.

Sincerely,
Tony Worden
Greenfield Co-operative Bank
Vice President - Commercial Lending