From: DOUG NEIGHBOR [mailto:Doug_Neighbor@fsbmail.net]
Sent: Monday, September 13, 2004 5:16 PM
To: Comments
Subject: RIN 3064-AC50
Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
500 17th Street NW
Washington, DC 20429
RE: Community Reinvestment Act Proposal
RIN 3064-AC50
Dear Mr. Feldman:
I am writing to support your proposal to increase the asset threshold for banks
to qualify for the streamlined examination procedures under the Community Reinvestment
Act.
I work for a community bank and do not feel that with seven locations my institution
is comparable to banks with several hundred locations and billions of dollars
in assets. It is extremely difficult for us to compete with billion-dollar
institutions for qualified investments that meet the requirements under large
bank CRA. The larger institutions have the money, manpower and technology to
outbid us. Too many times the efforts we put forth to meet investment goals
go unrecognized, as it is overshadowed by the performances of our billion-dollar “peers”.
Increasing the size of banks eligible for the small bank CRA exam will not
relieve banks from CRA responsibilities. The growth and survival of the bank
is intertwined with the growth and survival of the community. As a family owned,
community bank, our attitudes towards supporting the communities in which we
raise our families would remain unchanged. We would merely have a reduction
in reporting requirements and costs, freeing up more time and money that could
be better spent in the development of the community.
Today’s community banks are drowning in regulatory red tape, utilizing
valuable resources to meet regulatory compliance mandates that could be put
to much better use for economic and development purposes in the communities
in which we live and work. Thank you for recognizing this and proposing the
changes to the Community Reinvestment Act. If you have any questions in regards
to these comments, please feel free to contact me.