Robert E. Feldman, Executive Secetary
Attn: Comments
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC 20429
RE: 12 CFR Part 345
Re: Proposed Revisions to the Community Reinvestment Act
Regulations
I am writing to support the federal bank regulatory agencies'
proposal to enlarge the number of banks and savings associations that
will be examined under the small institutions Community Reinvestment Act
(CRA) examination. The agencies propose to increase the asset threshold
from $250 million to $500 million and to eliminate any consideration of
whether the small institution is owned by a holding company. This is
clearly a step in the right direction for CRA and I support these acts.
In looking at our bank, converting to the large institution
examination requires, among other things, that we devote additional
staff time to documenting services and investments, which we currently
do not do, and begin to geocode all of out loans that might have CRA
value. This imposes a dramatically higher regulatory burden that drains
both money and personnel away from helping to meet the credit needs of
our community.
In conclusion, I strongly support increasing the asset-size of banks
eligible for the small bank streamlined CRA examination process as a
vitally important step in revising and improving the CRA regulations and
in reducing regulatory burden. I also support eliminating the separate
holding company qualification for the small institution examination,
since it places small community banks that are part of a larger holding
company at a disadvantage of their peers.
Sincerely yours,
Mark A. Butterfield,
Vice President, CRA Officer
Roundbank
200 2nd St. NE
Waseca, MN
