| AMERICAN HERITAGE BANK
September 14, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Committee
550 17th Street N.W.
Washington, D.C. 20429
Re: Community Reinvestment, RIN number
3064-AC50; Proposal to Expand Eligibility
for streamlined CRA Exam
Mr. Feldman:
I am writing as a community banker in strong support of the FDIC’s
proposal to increase the asset size limit of the “big bank” CRA exam to
$1 billion.
This action would dramatically relieve an unnecessary burden on our
bank. We are a $460 million bank with 11 offices in nine small towns,
the largest of which has a population of 19,000 people.
Well over 90% of our loans are within our assessment area. We have no
higher objective than to try to build our communities, because the
welfare of bank is directly dependent on the welfare of our communities.
We have now gone through two “large bank” CRA exams. While the
helpfulness and quality of the examiners is not in question, the
examination itself is overwhelming, extremely burdensome, ineffective,
and costly. Just preparing for this exam and trying to prove ourselves
takes a great deal of valuable time away from our community efforts.
The exam leaves little room for innovation and actually encourages us
to make investments that take resources out of our community. We are
downgraded for activity that benefits the entire community and not just
low-to-moderate income geographies.
At our bank we go out and ram-rod local municipal bond elections,
held for community necessities. We work to pass the election, then we
bid low on the bonds so that our schools or towns get a good deal, then
we buy the bonds to hold in our portfolio. If that isn’t community
re-investment, then I don’t know what is. But I assure you, it is not
encouraged by the large bank CRA exam.
Community banks perform a valuable service but the “big bank” CRA
exam hurts our efforts. Please raise this threshold to $1 billion. By
doing so, the FDIC would greatly improve the prospects of small
business, small banks, and small towns.
Thank you for your consideration.
Sincerely,
Guy Berry
President |
