From: LYNN Ciha [mailto:Lynn_Ciha@fsbmail.net]
Sent: Monday, September 13, 2004 5:15 PM
To: Comments
Subject: RIN3064-AC50 (CRA)
Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
500 17th Street NW
Washington, DC 20429
RE: CRA Proposal RIN 3064-AC50
Dear Mr. Feldman:
Please accept this as my comment letter to support your proposed
increase to the small bank asset threshold from $250 million to $1
billion under the Community Reinvestment Act (CRA).
I work for a community bank and feel the regulatory burden placed
on our industry has increased substantially and this trend is continuing.
We stretching already limited resources in order to be able to comply
with requirements such as those for data reporting under CRA. It
is time to ease some of these burdens and I applaud the FDIC for
taking the initiative in doing so.
Increasing the size of banks eligible for the small bank CRA exam
will not relieve banks from CRA responsibilities. We understand the
importance of CRA and how vital it is to our community. The growth
and survival of the bank is dependent on the growth and survival
of the community. With these changes, we would merely have a reduction
in reporting requirements and costs, freeing up more time and money
that could be better spent in the development of the community.
I do not support the additional community development test for banks
between $250 million and $1 billion. Banks have had several consecutive
quarters of record growth. As this trend continues, more financial
institutions will continue to grow towards and surpass the $1 billion
mark, therefore subject to the large bank examination procedures.
It will be very burdensome for institutions under $1 billion currently
subject to large bank examination procedures to change to these new
requirements and then back to large bank requirements after they
reach $1 billion. However, I do support the addition of rural areas
to the definition of community development activity.
Thank you for allowing me to comment on this proposal.
