Federal Deposit
Insurance Corporation

In response to the issue of regulatory reduction:

 

I am the President of Hicksville Building, Loan and Savings Bank, a $71 million, 115 year-old state-chartered mutual savings bank located in rural NW Ohio. 

 

I have read the EGRPRA "Summary of Top Ten Issues - Derived from Banker Outreach Meetings" and "Issues to Consider."  I  must say I wholeheartedly concur with the regs identified and the corresponding "Banker Suggestions."  In my 19 year tenure here at the bank, I have witnessed an explosion of regulatory requirements, particularly over the past five years (post 9-1-1 and Enron).  It is hard for me to imagine another industry so highly regulated as banking and on behalf of all the "small" institutions (those $150 million and less) I can unequivocally say that the burden created both in terms of time and expense are particularly taxing.   Everyone at a small institution wears multiple "hats" as we do not have the staffing or resources for specialized departments.  Consequently, I believe staff at small banks spend a lot of time shifting their attention from one area to another and are forced to be "generalists."  The compliance function by its very nature requires a good deal of specialization, thus the rub.  As a result, I believe small banks are forced to outsource various elements of the compliance function to third party vendors and incur corresponding costs.  I would estimate that our bank is spending an additional $50K annually as a result of third party services we have put in place to address compliance and regulatory initiatives.  In addition, it seems that industry is subject to a continual "raising of the bar" with no real end in sight.

 

Reduction of regulatory burden would assist banks of all sizes in re-focusing on their core mission:
meeting the financial needs of the public while providing value to stakeholders at all levels.   

Jamie R. Shinabarger
President/CEO