As President
of a small Community Bank in Southern Illinois, I am very much
in favor of
changing the "small bank" assets
size for CRA. I feel no matter what size a bank is in rural areas
of Illinois, we are either involved in community reinvestments or
you will not stay in business. I applaud the FDIC and OTS for these
efforts in raising the threshold from 5250,000,000.00 to one billion.
Naturally customers and concerned groups should be concerned that
the level of service by the Bank and its employees will change. Quite
frankly it will not and cannot for the reasons stated above,
The main reason
for change is the amount of paperwork a large bank is forced to
submit, the
collections of data, purchase of software
and possible employment of workers to run the program. Let's understand
the reason we have CRA — will large bank data change the job
small banks do everyday — being involved with the community
they serve.
We are already inundated with paperwork that very much affects the
bank but not the service we provide.
Sincerely,
Dale G. Deiters CEO/President
Germantown Trust & Savings Bank
