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FDIC Federal Register Citations

Farmers State Bank

April 8, 2004

Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
500 17th Street NW
Washington, DC 20429

RE: Community Reinvestment Act Proposal

To whom it may concern:

I am a community banker working for a financial institution located in Marion, Iowa. I appreciate the opportunity to comment on the proposed amendments to the Community Reinvestment Act (CRA).

While I support your proposal to increase the asset size for banks eligible to be examined under the CRA small bank test to $500 million, I urge you to consider increasing that threshold to $1 billion. Our financial institution is quickly growing towards the $500 million mark, and I do not feel that with seven locations we are comparable to banks with several hundred locations and billions of dollars in assets. It is extremely difficult for a bank of our size to compete with billion-dollar institutions for qualified investments that meet the requirements under large bank CRA. The larger institutions have the money, manpower and technology to beat us every time. Too many times the effort we put forth to meet investment goals goes unrecognized, as it is overshadowed by the performances of our billion-dollar “peers”.

I also support the elimination of the bank holding company asset size threshold. Many banks maintain their own charter, management and operational processes when purchased by a large holding company. They “inherit” the regulatory requirements of the holding company but do not always benefit from the holding company’s resources for complying with these requirements.

Increasing the size of banks eligible for the small bank CRA exam does not relieve banks from CRA responsibilities. The growth and survival of the bank is intertwined with the growth and survival of the community. Working at a family owned, community bank, my attitude towards supporting the community in which I call home would remain unchanged. The bank 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.

Today’s community banks are drowning in regulatory red tape, utilizing valuable resources to meet regulatory compliance mandates that could be put to much better use for economic and development purposes in the communities in which we live and work. Thank you for recognizing this and proposing the changes to the Community Reinvestment Act. If you have any questions in regards to these comments, please feel free to contact me.

Sincerely,

Debby A. Roth
Vice President REO
Farmers State Bank
1240 8th Avenue
Marion, IA 52302
319-377-4891 X1080
debroth@fsbmail.net

Last Updated 04/30/2004 regs@fdic.gov

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