From: Stephen Godar [mailto:stephengodar@fsbmail.net]
Sent: Tuesday, September 14, 2004 7:30 AM
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: Community Reinvestment Act Proposal
RIN 3064-AC50
Dear Mr. Feldman:
I appreciate being able to comment on your proposed changes to the
Community Reinvestment Act (CRA). Please accept this letter as support
for your proposal to change the small bank asset threshold from $250
million to $1 billion.
As a community
banker I understand the regulatory burden CRA places on our industry.
Continuing costs of software, software upgrades
and personnel needed to comply with the data recording requirements
of CRA alone use up resources that could be better spent on the development
of the community. There are a limited number of qualified investments
in our communities. Billion dollar institutions have the money and
manpower required to be successful in gaining these investments over
smaller institutions. Yet, when regulatory agencies examine us under
CRA, we are compared to those institutions as our “peers”.
There is just no comparison.
I urge the FDIC to take this opportunity to ease the burden of this
regulation on our community banks. Therefore, I do not support the
addition of any new community development tests that would further
complicate this.
