FIRST CITIZENS NATIONAL BANK
From: Doug Whitten [mailto:dwhitten@firstcitizensbank.com]
Sent: Thursday, September 16, 2004 9:36 AM
To: Comments
Subject: RIN No. 3064-AC50
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
I support the FDIC proposed increase of the threshold for the small
bank streamlined CRA examination from under $250 million in assets to
under $1 billion, without regard to the size of the bank’s holding
company. Our bank is a $500 million dollar bank in rural north central
Pennsylvania. We have and will continue to have a strong interest in
supporting community development. We do this not because it is the law
but because it is good business. The reporting and tracking burden only
detracts from our ability to support our communities.
I strongly support the FDIC’s proposal to change the definition of
“community development” from only focusing on low- and moderate-income
area residents to including rural residents. This change will go a long
way toward eliminating the current distortions in the regulations that
result in a small rural bank being told to invest in regional affordable
housing bonds for an urban area not in the bank’s community.
I strongly oppose making the Community Development (CD) criterion a
separate test from the bank’s overall CRA evaluation. For a community
bank, CD lending is not significantly different from the provision of
credit to the entire community. The current small bank test considers
the institution’s overall lending in its community. The addition of a
category of CD lending (and services to aid lending and investments as a
substitute for lending) fits well within the concept of serving the
whole community. A separate test would create an additional CD
obligation and regulatory burden that would erode the benefit of the
streamlined exam.
In conclusion, I believe that the FDIC has proposed a major
improvement in the CRA regulations, one that much more closely aligns
the regulations with the Community Reinvestment Act itself, and I urge
the FDIC to adopt its proposal, with the recommendations above. I will
be happy to discuss these issues further with you, if that would be
helpful.
Douglas W. Whitten
VP Operations Division Manager
First Citizens National Bank
1163 South Main Street
Mansfield, PA 16933
