Community
Bankers Association of Ohio
September 1, 2004
Scott M. Polakoff
Regional Director
Federal Deposit Insurance Corporation
500 West Monroe Street
Suite 3500
Chicago, IL 60661
Dear Scott,
The Community
Bankers Association of Ohio (CBAO) is Ohio's oldest statewide financial
trade association representing Independent Community
Bank and Thrift Institutions. CBAO Members serve their communities
through 625 locations, with over 7,000 employees in Ohio. Members
collectively hold $23 Billion in assets, $18 Billion in insured
deposits and $15 Billion in net loans.
We appreciate
the FDIC issuing a new proposal to solicit additional comments
on the impact of changing the definition of a small bank
for purposes of CRA to include those with total assets of up to
$1 billion, regardless of holding company affiliation.
The CBAO and its Financial Membership strongly supports your proposal
to increase the size limit for community financial institutions eligible
for the small bank streamlined Community Reinvestment Act Examination from $250 mullion to $1 billion. We also support establishing
a community development test which would permit more choice for our
financial institutions to be evaluated based upon their community
development lending, qualified
investments or community development services, as opposed to all
three. This proposal would also help our community focused financial
institutions to better compete with multibillion-dollar financial
institutions for qualified investments.
The FDIC proposal would replicate the recently finalized OTS rule,
which raises the limit to $1 billion, effective October 01, 2004.
The proposed changes will not undermine the intended purpose of
CRA and would ease the paperwork and examination burden on approximately
280 community financial institutions in the state of Ohio.
Sincerely,
Robert L. Palmer
President and Chief Executive Officer
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