From: Jess Laird [mailto:JLaird@FSBAthens.com]
Sent: Tuesday, April 06, 2004 7:44 PM
To: Comments
Subject: 12 CFR Part 345, RIN 3064-AC50
Regarding the
joint proposal to amend the Community Reinvestment Act, I would
like to comment
that I am in favor of changing the definition
of “small institution” to mean an institution with total
assets of less than $500 million, without regard to holding company
assets. I have been told that a bill has been introduced in Congress
proposing the level be raised to $1 billion. Given a choice, I would
support this proposal over the $500 million proposal.
In my twenty years of working in community banks and the financial
industry, I strongly believe that community banks as a whole are
dedicated to the ideals and goals of the Community Reinvestment
Act. I do not believe the large bank CRA exam as it now stands;
particularly the loan, service, and especially the investment test
are either fair or an efficient way to measure compliance with
CRA.
In my opinion, raising the level to either $500MM or $1B will not
diminish community bank’s compliance with the goals of CRA.
Raising the levels will save significant resources which can be
better applied.
Thank you for your consideration.
Jess Laird, President
First State Bank
Athens, Texas 75751