Franklin Savings Bank
From: Magoon, Ronald [mailto:Magoon@fsbnh.com]
Sent: Thursday, September 16, 2004 9:57 AM
To: Comments
Cc: 'psmith@aba.com'
Subject: RIN No. 3064-AC50
Mr. Robert E. Feldman
Executive Secretary
FDIC
Dear Sir:
I am the Senior Vice President, Treasurer and CFO of Franklin Savings
Bank in Franklin, New Hampshire. My bank serves many small communities
in Central New Hampshire; with our headquarters located in a small
city with under 9,000 residents. Franklin Savings has 6 offices and
$273 million in assets.
I am writing to 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 the small banks under the
current regulation. Community banks would still be required to help
meet the credit needs of their entire communities and would continue
to be so evaluated by their regulator.
As I write this email, our bank is in the middle of a two week long
charity softball tournament that we sponsor. This is the eleventh
year we have held this softball tournament. Local organizations enter
coed teams to compete in this event. Local organizations donate food
and drinks to be sold in the concession stand. Local organizations
donate giveaways for the raffle. Franklin Savings Bank enters a team
in the tournament, sells raffle tickets, organizes all aspects of
the tournament from scheduling the umpires to raking the field, and
employees man the concession stand. All monies raised from this event
go to local charities. This year we are playing for local soup kitchens.
Franklin Savings Bank created a $1 million Fund for Community Advancement
in 1997. This Fund provides grant monies to local non-profit organizations
to support a wide variety of causes including: families in crisis,
community development projects, community mental health, building
funds for libraries, improvements to ballparks, specially equipped
vans to transport the elderly, and the list goes on.
As you can see from just these two examples - we are what community
banking is all about. Unfortunately, we often don't receive "credit" for
the countless hours and considerable dollars that we (and our employees)
contribute to our communities. However if you were to ask those in
our communities about Franklin Savings Bank, I sincerely believe
you would hear just how important we are to those who live here.
I strongly support the FDIC's proposal to change the definition of "community
development" from only focusing on low and moderate income area
residents to including rural residents. This change will go a long
way toward eliminating the current distortions in the regulations
that result in a small rural bank being told to invest in regional
affordable housing bonds for an urban area not in our community.
I do, however, think this change in "community development" criterion
should apply to banks much larger than Franklin Savings Bank. I believe
the FDIC should adopt its original $500 million threshold for small
bank examinations, and apply the community development criterion
to banks between $500 and $1 billion in assets as an additional component
of the small bank exam.
As a small community bank, we have limited financial resources. As
you can see from this correspondence, our preference is to do as
much as possible for those living in our communities. The more we
spend to comply with the myriad of regulations that we much contend
with each and every day, the less time and money can be given back
to those truly in need.
I encourage the FDIC to consider my comments thoughtfully so that
we may continue to do what we do best - community banking.
I would welcome further questions or comments on this matter.
Respectfully submitted,
Ronald L. Magoon
SVP, Treasurer & CFO
Franklin Savings Bank
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