Mr. Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Mr. Feldman:
As a President
of a local community bank I am strongly endorsing 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 the
elimination of the holding company size limit. This proposal will
greatly reduce the regulatory burden that we continually are required
to deal with. As a $150 million bank located in Logansport, Indiana
we are finding these burdens to be increasingly troublesome.
The small bank
CRA examination process is an excellent innovation. This will allow
local community
banks to focus on what they do best
without the requirements of the large bank CRA evaluation process
and associated costs. Resources devoted to the current CRA exam process
would be more beneficial
if devoted
to our local community.
Banks should
be evaluated against their peers not against banks many times their
size. We also feel it is not fair to rate community
banks using the same CRA examination used for large banks. We feel
that changing the CRA examination process does not relieve banks
from their CRA responsibilities. As the survival of many community
banks is closely intertwined with the success and viability of their
communities the change in process will merely eliminate some of
the most burdensome requirements.
In summary I
believe changing the CRA examination process is an important step
to reducing regulatory burden. I would recommend that
banks eligible for the streamlined examination approach be at a targeted
level no less than $1 billion in assets. This change will help eliminate some of the most problematic and burdensome elements
of the CRA regulation.
Sincerely
David G. Wihebrink
President
Logansport Savings Bank
Logansport, IN
