Robert E. Feldman, Executive Secretary
Attn: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
RE: 12 CFR Part 345
Dear Mr. Feldman:
I am writing to support the federal bank regulatory agencies'
(Agencies) proposal to enlarge the number of banks and saving
associations that will be examined under the small institution Community
Reinvestment Act (CRA) examination. The Agencies propose to increase the
asset threshold from $250 million to $500 million and to eliminate any
consideration of whether the small institution is owned by a holding
company. This proposal is clearly a major step towards an appropriate
implementation of the Community Reinvestment Act and should greatly
reduce regulatory burden on those institutions newly made eligible for
the small institution examination, and I strongly support both of them.
I believe that it is as true today as it was in 1995, and in 1977
when Congress enacted CRA, that a community bank meets the credit needs
of its community if it makes a certain amount of loans relative to
deposits taken. A community bank is typically non-complex; it takes
deposits and makes loans. Its business activities are usually focused on
small, defined geographic areas where the bank is known in the
community. The small institution examination accurately captures the
information necessary for examiners to assess whether a community bank
is helping to meet the credit needs of its community, and nothing more
is required to satisfy the Act.
Sincerely,
Donald Janda
President
Bank of St. Edward
Box D
St. Edward, NE
