From: Allan Houston [mailto:ahouston@fidelitybankonline.com]
Sent: Friday, September 17, 2004 1:41 PM
To: Comments
Subject: RIN #3064-AL50
Robert E. Feldman, Executive Secretary
Attn: Comments
Federal Deposit Insurance Corporation
550 17th Street North West
Washington, DC 20429
Subject: Community Reinvestment RIN 3064-AC50
Dear Mr. Feldman:
I am the SVP of Residential Lending and CRA Officer at the Fidelity
Bank, Fitchburg, MA, a $300 million bank. I believe the CRA revisions
are both welcome and appropriate. I would however urge the FDIC to
adopt a $500 million up to $1 billion threshold for small banks to
have a community development criterion. I think this is appropriate
understanding the level of resources of our Bank and of Bank’s
our size coupled with the fact that the current small bank lending
criterion adequately captures the most vital evidence of a small
bank’s contribution to the community it serves, lending.
Also,
for purposes of lowering the regulatory burden of the law, requiring
a community development test at a level lower than $500 million substantially
lessens the benefit of the revisions.
Additional banks under $500 million now hold about the same percent
of overall industry assets as community banks under $250 million
did a decade ago when the revised CRA regulations were adopted, so
this adjustment in the CRA threshold is appropriate without an additional
criterion.
In conclusion the FDIC proposal is welcome and one that continues
to align the interest all concerned. I do believe that setting the
thresholds as indicated above would accomplish the desired regulatory
benefits without diminishing the value of the law to the communities
being served.
