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 appreciate your requesting input concerning proposed changes in
the Community Reinvestment Act.
I have been a community banker for several years and recognize the
need for regulatory burden relief in institutions like mine. Banks
are growing at record rates and for many, the proposed $1 billion
threshold will not be far off. However, the relief provided to these
institutions now is invaluable. Resources saved could be allocated
towards products and services that would benefit our communities.
Implementing additional community development criterion for banks
with asset levels between $250 million and $1 billion would, however,
defeat the purpose of this proposal. Resources thought to be saved
would end up being channeled right back into compliance efforts in
order to meet these requirements.
I appreciate and support the intent of the Community Reinvestment
Act and realize it is of great importance to communities across the
country. I do not feel, as some of the other comment letters suggest,
that these proposed changes would undermine the intent of CRA. The
Community Reinvestment Act is not being repealed under these proposals.
Financial institutions would still have a responsibility under the
regulation to support our communities.