From: Larry Johnson [mailto:Larry_Johnson@fsbmail.net]
Sent: Monday, September 13, 2004 5:43 PM
To: Comments
Subject: RIN3064-AC50 (CRA)
Dear Mr. Feldman:
I appreciate being able to comment on your proposed changes to
the Community Reinvestment Act (CRA).
In reviewing some of the comments already posted to your site,
it is clearly expressed in most letters from community bankers
that 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. 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. CRA is not being repealed here. 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. If the
goal of some of those commenting here is to make everyone a homeowner,
I encourage them to use their letter writing abilities to petition
Congress to broaden CRA responsibilities by including credit unions
and mortgage companies as well in order to make that dream a reality.
I applaud the FDIC for taking a leadership role and proposing this
amendment to CRA.
