First Security Bank
March 26, 2004
Robert E. Feldman, Executive Secretary
Attn: Comments, Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: Community Reinvestment Act Regulations
Dear Mr. Feldman:
I am writing to represent First Security Bank, a $400 million
community bank in southwest Montana. As the Community Reinvestment Act
officer of this bank, I am well aware of the proposal to increase the
asset size eligibility of banks for the "small bank" streamlined exam.
I solidly endorse the bank regulators' proposal. Increasing the asset
size of eligible banks from $250 million to $500 million (and the
elimination of the holding company size limit) is a strong step in the
right direction. However, I further encourage the regulators to lift the
CRA small bank threshold to $1 billion.
In the current environment of mega-banks and billion-dollar mergers,
community banks are left in a very difficult position. Community bankers
must already bear a stifling regulatory burden with resources that are
far smaller than their massive counterparts. To further classify a $500
million bank into the same "peer group" as a multi-billion dollar
institution is simply unfair.
Ironically, community activists object to bank mergers that remove
the local bank from the community, but seem oblivious to the burdens
placed on community banks. If community groups want to keep the local
banks in the community where they have better access to decision-makers,
they must recognize that regulatory burdens are strangling smaller
institutions and forcing them to consider selling to larger institutions
that can better manage the burdens.
Increasing the eligibility size of small banks for the streamlined
exam will in no way relieve our bank from CRA responsibilities. This
bank has worked very hard to achieve its history of "Outstanding" exams,
and will continue to work hard to support the success and viability of
our community. Please do not undercut our efforts by comparing them to
those of an institution hundreds of times our size.
Respectfully,
Rebekah F. Leonard
CRA / Compliance Officer
First Security Bank
Bozeman, MT
