From: Diane Foltz [mailto:Diane_Foltz@fsbmail.net]
Sent: Monday, September 13, 2004 12:10 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
Dear Mr. Feldman:
I am writing on behalf of Farmers State Bank in Marion, Iowa. We
are a $437 million institution with seven offices in our county.
I appreciate being able to comment on your proposed changes to
the Community Reinvestment Act (CRA).
In preparation for writing this letter, I took time to review some
of the comments already posted to your site. As it is clearly expressed
in most letters from community bankers, regulatory issues have
placed a large burden upon our industry. USA PATRIOT Act, Check
21, CAN SPAM and FACTA are some of the new regulatory issues we
have had to add to our workloads in just the past twelve months.
In addition to that, we have had major changes to Regulation B
and Regulation C along with minor changes to several other regulations.
For Compliance Officers and Managers, it is getting more and more
difficult to keep up with the never-ending changes and data reporting
requirements. And, as you can see by looking at several of the
comment letters, compliance is often just one of the many "hats" community
bankers wear. Many times compliance duties are in addition to lending,
BSA, security and/or internal auditing. I feel strongly that it
is time to give banks some relief. With that being said I would
like to express my strong support for reducing the regulatory burdens
of CRA on financial institutions and increasing the small bank
asset size threshold from $250 million to $1 billion.
More than one comment letter submitted seemed to think that by
reducing the number of banks examined under the large bank rules,
those banks would suddenly be relieved of all requirements under
CRA. And, that suddenly our support for the communities in which
we live and work would cease. This is absolutely untrue. No banker
is disputing the importance of CRA. We know what our industry contributes
is vital to our communities and that it must continue. Community
banks will not survive if those communities don't thrive. However,
banks could afford relief in the way of a less rigorous exam and
eased reporting requirements. Ongoing costs of software and personnel
required to maintain CRA data stretch already limited resources.
This information is coded internally by most institutions and can
be pulled if necessary instead of subjecting financial institutions
to the excessive record keeping requirements of today. Also, many
dwelling secured small business and small farm loans are covered
and recorded under the new HMDA requirements. That data will show
lending practices to minority and women owned businesses. I am
not in support of the new community development test for institutions
between $250 million and $1 billion, but if is the only way to
meet in the middle, I will accept it as it is more flexible than
today's requirements.
In conclusion, I would like to state that staff have told me how
the joy of being in the banking industry is starting to slip away.
We got into this industry to assist people with their financial
needs only to end up afraid to do so with threats of violations
and penalties looming from the many regulations we are required
to comply with each day. I applaud the FDIC for taking a leadership
role in addressing this issue and trying to make a difference in
the industry.
