From: Lehman, Gene [mailto:glehman@TheUBank.com]
Sent: Friday, September 17, 2004 1:15 PM
To: Comments
Cc: psmith@aba.com
Subject: FDIC CRA Proposal
September 17, 2004
Federal Deposit Insurance Corporation
To Whom It May Concern:
We strongly support the FDIC's proposal to raise the threshold for
the streamlined small bank CRA examination to $1 billion without
regard to the size of the bank's holding company.
As a rural bank, we 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.
As a community bank, our success is firmly tied to the success of
the communities we serve. We believe that community banks should
be required to help meet the credit needs of their entire communities
and should continue to be so evaluated by their regulator.
Anything that the FDIC can do to reduce regulatory burden and the
costly overhead required to comply with that burden will directly
benefit the community banking industry's attempt to generate profits
and increase capital thereby reducing risk to the deposit insurance
fund. Slow-growth rural communities are especially vulnerable to
price competition from less regulated out of market non-bank specialty
shops such as mortgage brokers, credit card lenders, captive finance
companies, regional credit unions, etc. The ability to continually
layer new compliance overhead on a stagnant earning asset base is
quantifiable and limited. Regulatory excess contributes to the consolidation
trend in banking, thereby reducing community employment and responsiveness
to community credit needs.
Thank you for you efforts on our behalf.
Sincerely,
E. Eugene Lehman,
President The Union Bank Company, Columbus Grove,
Ohio
