From: Marie Doty [mailto:marie.doty@towerbank.net]
Sent: Thursday, September 16, 2004 1:09 PM
To: Comments
Cc: 'psmith@aba.com'
Subject: RIB No. 3064-AC50
Mr. Feldman:
I am writing to support the FDIC's proposal to raise the threshold
for the small bank CRA examination to $1 billion without regard
to the size of the bank's holding company.
Our bank is a $467 million bank located in Fort Wayne, Indiana. We
are currently and newly subject to the large-bank CRA exam for the
first time. The regulatory burden imposed on our bank due to the
large CRA bank status has been enormous to us. This is the same standard
that the Wells Fargo, National City and Bank One institutions in
this city are held to with their enormous monetary and human resources.
We have had to completely reorganize our programs, hire additional
staff, begin massive new reporting, and monitoring has been costly
in professional fees. All the while trying to compete with institutions
like Wells Fargo, National City, and Bank One in this community,
and Chase and the other trillion dollar institutions in other communities.
The disparity is of extensive significance and consequence to the
smaller community financial institutions.
In all fairness regarding the regulatory burden imposed, this proposal
would be far more appropriate to the size of our bank and other similar-sized
financial institutions than subjecting us to the same standards and
requirements that apply to the trillion dollar institutions.
I strongly urge the FDIC to adopt its proposal, and am hopeful the
other agencies will follow . I very much appreciate your consideration.
Marie A Doty
Vice President
Compliance and Internal Audit
Tower Bank & Trust Co.
116 East Berry Street
Fort Wayne, Indiana
