Robert E. Feldman, Executive Secretary
Attention: Comments
FDIC
550 17th Street
Washington, DC
Re: Community Reinvestment Act Regulations
Dear Sir or Madam:
I am the President of a $220 million bank located in Troy, Ohio. As a
community banker, I strongly endorse the federal bank regulators'
proposal to increase the asset size of banks eligible for the small bank
streamlined Community Reinvestment Act (CRA) examination from $250
million to $500 million and elimination of the holding company size
limit (currently $1 billion). This proposal will greatly reduce our
regulatory burden.
As a community banker, I applaud the agencies for recognizing that it
is time to expand this critical burden reduction to larger community
banks. At our bank approaches the $250 million threshold, this change
will allow us to focus on what we do best – making loans in our
community. If we must comply with the requirements of the large bank CRA
evaluation process, our costs would increase dramatically and the
resources we devote to CRA compliance are resources not available for
meeting the credit demands of our community.
A local community bank like ours is essential to the growth and well
being of our community. Our management and Board are involved at all
levels in projects that make our community a better place to live. If we
want to keep the local banks in the community where customers have
better access to decision-makers, we 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 size of banks eligible for the small-bank streamlined
CRA examination does not relieve banks from CRA responsibilities. Since
the survival of our bank is closely intertwined with the success and
viability of our community, the increase will merely eliminate some of
the most burdensome requirements.
In summary, I believe that increasing the asset-size of banks
eligible for the small bank streamlined CRA examination process is an
important first step to reducing regulatory burden. I also support
eliminating the separate holding company qualification for the
streamlined examination, since it places small community banks that are
part of a larger holding company at a disadvantage to their peers. While
community banks still must comply with the general requirements of CRA,
this change will eliminate some of the most problematic and burdensome
elements of the current CRA regulation from community banks that are
drowning in regulatory red-tape. Thank you for your leadership in this
area of concern.
Sincerely,
Ronald B. Scott
President
