Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064A-AC50: FDIC Proposed Increase in the Threshold
for the Small Bank CRA Streamlined Examination
Dear Mr. Feldman,
I am Director
of Compliance, Internal Audit and Loan Review for Grabill Bank,
located in a small
farming community of around 1,000
residents. My bank has assets just over $500,000,000 and is subject
to large bank CRA exam procedures. I am writing to strongly support
the FDIC’s proposal to raise the threshold for the streamlined
small bank CRA examination to $1 billion without regard to the size
of the bank’s holding company. This would greatly relieve the
regulatory burden imposed on many small banks such as my own under
the current regulation, which are required to meet the standards
imposed on the nation’s largest $1 trillion banks. I understand
that this is not an exemption from CRA and that my bank would still
have to help meet the credit needs of its entire community and be
evaluated by my regulator. However, I believe that this would lower
my current regulatory burden significantly.
I believe that the FDIC has proposed a major improvement in the
CRA regulations, one that much more closely aligns the regulations
with the Community Reinvestment Act itself, and I urge the FDIC to
adopt its proposal.
Sincerely,
Michael M. Gonya
Director of Compliance, Loan Review and Auditing
