As a community banker, I strongly endorse the federal bank
regulators proposal to increase the asset size of bank eligible for the
small bank streamlined Community Reinvestment Act (CRA) examination from
$250 million to $500 million and elimination of the holding company size
limit. This proposal will greatly reduce regulatory burden. I am the
President and CEO of Citizens Bank of Blount County, a $242 million
asset bank located in Maryville, Tennessee.
With all the mergers and conglomerate banks, the definition of small
bank has certainly changed. With this change, the definition of a small
bank as defined in the CRA examination process should also be modified.
Community banks find it difficult enough competing with $500 billion
banks surrounding them. When regulators lump our banks with these huge
institutions, it restricts us from doing the very thing CRA was intended
for, and that is to serve our communities. Raising the CRA small bank
ceiling will support the survival of community banks. Survival of the
community bank will strengthen the communities we serve.
In summary, I believe that increasing the asset-size of banks
eligible for the small bank streamlined CRA examination process is an
important first step to reducing regulatory burden. I would further urge
agencies to seriously consider raising this asset-size to at least $1
billion to better reflect the current demographics of the banking
industry.
Sincerely,
Joe Bruce
President & Chief Executive Officer
Citizens Bank of Blount County
Maryville, TN