From: Paul C. Adamski
[mailto:pineries@charter.net]
Sent: Monday, April 05, 2004 11:05 AM
To: Comments
Subject: Community Reinvestment Act Regulation
Paul C. Adamski
3601 Main St.
Stevens Point, WI 54481
April 5, 2004
Dear FDIC:
Please accept this correspondence as my comment letter urging your
agency to increase the asset size of banks eligible for the small bank
streamlined Community Reinvestment Act (CRA) examination from $250
million to $500 million. I also understand that this proposal would
eliminate the holding company size limit (currently $1 billion).
Obviously this proposal would greatly reduce regulatory burden.
Approximately eight years ago a group of investors and I purchased
the smallest bank in the state for the purpose of growing that bank in
its original market and in a new market(ie, Stevens Point, WI). During
that time we have worked hard to keep a loan to deposit ratio that has
typically ranged from 75% to 83% It is our opinion that consistent high
loan to deposit ratios of this type speak for themselevs when it comes
time for regulators to determine how a financial institution is meeting
the needs of its communities.
We would also suggest that adjusting the asset size limit is
appropriate at this time because it more accurately reflects significant
changes and consolidation within the banking industry in the last 10
years. When I first started in the banking business every bank in
Portage County Wisconsin was independently owned and operated. Obviously
time and legislation have changed that situation signifcantly. Now is
the time to recognize that banks should not all be examined and subject
to the exact same types of regulations. This proposal is a significant
step in that direction.
I applaud your agencies initiative to bring this streamlined CRA
proposal to the forfront and encourage you to take similar measures in
other areas of regulation that will prudently reduce the regulatory
burden for community banks throughout the nation.