September 15, 2004 Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: FDIC Proposed Increase in the Threshold for the Small Bank CRA
Streamlined Examination (RIN Number 3064-AC50)
Dear Mr. Feldman:
The North Carolina Bankers Association, on behalf of its 140 member
banks and savings institutions headquartered or doing business in North
Carolina, appreciates the opportunity to comment with respect to the
FDIC’s proposal to raise the asset threshold for what constitutes a
“small bank” under the agency’s CRA rules. The Association strongly
supports the proposal to increase the small bank asset threshold to $1
billion without regard to an institution’s holding company affiliation.
With respect to the proposed addition of a community development
criterion to the streamlined evaluation method for small banks, the
Association recommends that such criterion apply to small banks with
assets greater than $500 million and up to $1 billion, rather than to
those having assets greater than $250 to $1 billion as currently
proposed. Too, the community development criterion should not be made a
test separate from a bank’s overall CRA evaluation. Finally, the
Association supports the proposal to amend the definition of “community
development” to encompass a broader range of activities in rural areas.
The FDIC is urged to follow the OTS’s lead in adopting rules
increasing the small institution asset threshold to $1 billion. In
addition to recognizing industry growth since the small bank threshold
of $250 million was established in 1995, such action would help ensure
consistency and uniformity in the application of the supervisory
agencies’ CRA rules.
Sincerely,
Edmund D. Aycock
Senior Vice President and Regulatory Counsel
