From: Kimberly F Higgins
Sent: Monday, September 13, 2004 9:11 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
The Bank of
Georgia is a community bank that has grown to an asset size of
$238 million
in less than five years. Such growth would
have been impossible without the support of and our investment
in our community. As a bank approaching the $250 million mark,
we strongly support the FDIC’s proposal to raise the “small
bank” threshold to $1 billion.
After reading many of the comments regarding this proposal, it
is apparent that many feel that this proposal is going to “do
away with” or repeal the Community Reinvestment Act. We understand
that this is not the case; the proposed increased threshold will
alleviate some of the more burdensome reporting and record keeping
requirements for small institutions, not undermine the CRA.
A $250 million bank of today is certainly not the same as a $250
million dollar bank of twenty years ago. Today, an institution of
that size is truly a “small bank”. If we are classified
as a large institution, it will require the purchase of expensive
record keeping software and the hiring of additional staff to comply
with the reporting requirements. Recent years have already added
a significant compliance burden to the financial industry with the
Gramm-Leach-Bliley Act and the US PATRIOT Act. While we wholly support
the spirit of these regulations, and that of the CRA, the regulatory
burden of compliance has a much greater impact on a small institution
than on a larger one.
We do oppose the addition of a mandatory community development performance
criterion for banks with assets between $250 million and $1 billion.
The proposal does not explain what this criterion would be, and we
fear that this too could result in additional regulatory burden.
We especially oppose any criterion that would establish an arbitrary
ratio or number to be used in evaluating an institution’s community
investment activities. We believe that these activities should be
judged subjectively on the opportunities within the institution’s
community and compared with the institution’s peers, rather
than compared to a national average that takes into account areas
with significantly different CRA opportunities.
Thank you for the opportunity to comment on this proposal.
Sincerely,
Pat Shepherd
President and CEO
The Bank of Georgia
Peachtree City, GA
