Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50
Dear Mr. Feldman:
Our bank is a fifteen-year-old community bank with approximately $560
million in assets.
We 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 currently imposed on small banks, which are now
required to meet the same standards imposed on the nation’s largest $1
trillion banks.
We also support the addition of a community development criterion to
the small bank examination for larger community banks, but we believe
that the FDIC should adopt its original $500 million threshold without a
community development criterion. The new community development criterion
should be applied only to banks greater than $500 million up to $1
billion. As field examiners know, it has proven extremely difficult for
small banks to find appropriate CRA qualified investments in their
communities.
We thank you for recognizing that “one size does not fit all” when it
comes to CRA, and we urge you to adopt your proposal.
