Federal Deposit
Insurance Corporation

Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D.C. 20429

Dear Mr. Feldman:

I am writing to express my support for the proposed changes to CRA regulations which would amend the definition of a “small institution” to mean an institution with total assets of less than $500 million. I presently serve as the Senior Lending Officer of a publicly traded, state chartered thrift institution that is approaching the $250 million asset mark. One wears many hats in an institution of this size, and among the hats I wear is that of the bank’s CRA officer. Our CFO serves as the bank’s compliance officer. We are not of a size that we believe can support an individual devoted to compliance, and we outsource our compliance audit function.

As a small, community bank, we face many challenges in our effort to remain competitive with the larger institutions in our market. One of the more daunting of these challenges is the regulatory compliance burden. While economies of scale allow larger institutions to have specialized personnel and departments devoted to the compliance function, it is simply not practical for a bank our size. Yet in nearly all compliance areas, we are expected to be fully knowledgeable, with comprehensive procedures and systems in place to satisfy the myriad requirements contained in thousands and thousands of pages of regulations. CRA is one of the few areas where our size is taken into account and, in my opinion, sensibly so.

It is my strong belief that our institution fulfills its CRA obligations by simply doing business the way we always have. We make home mortgages and small business loans and mortgages, largely within our assessment area. We consistently receive high marks for lending to borrowers of different incomes and in low to moderate income census tracts. We do these things not because we are required to under CRA; rather, it is simply the business we are in.

I do not see any benefit to the community that will accrue from the more intensive record keeping and reporting requirements that will apply once we cross the $250 million threshold. If anything, it will just make it more difficult to continue doing the good job we are already doing. It is for these reasons that I support the proposed changes.

Thank you.

Mayflower Cooperative Bank
John J. Biggio
Vice President
Senior Loan Officer
Telephone: 508-947-4343