Skip Header

Federal Deposit
Insurance Corporation

Each depositor insured to at least $250,000 per insured bank



Home > Regulation & Examinations > Laws & Regulations > FDIC Federal Register Citations




FDIC Federal Register Citations


NORTHPOINTE BANK



From: Tom Sall [mailto:TOMS@npbank.com]
Sent: Tuesday, March 30, 2004 2:44 PM
To: Comments
Subject: Proposed CRA Amendments Comment

Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
comments@fdic.gov


Re: Community Reinvestment Act Regulations


Dear Mr. Feldman:

I am the Compliance Officer for a $200 million bank located in Grand Rapids, Michigan. I wish to voice my support for 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. I also support the elimination of the $1 billion holding company size limit.

I am in favor of this proposal because it will greatly reduce regulatory burden and will free up more resources for community banks to do what they should be doing under CRA – meeting the credit needs of their local communities. The proposed change also recognizes that it's not right or fair to assess the CRA performance of a $500 million bank with the same exam procedures used for a $500 billion bank. Furthermore, I believe that the asset size limit, once it is increased to $500 million, should be increased on an annual basis in the same way that the asset threshold for Home Mortgage Disclosure Act reporting is increased (under Federal Reserve Regulation C).

Increasing the asset size of banks eligible for the small-bank streamlined CRA examinationwill not relieve banks from their CRA responsibilities. On the contrary, since the survival of many community banks, including Northpointe Bank, depends upon the success and viability of their communities, the increase will merely eliminate some of the most burdensome requirements.

Thank you.

Thomas Small
Vice President, Risk Mgt
Northpointe Bank

 

Last Updated 04/02/2004 regs@fdic.gov

Skip Footer back to content