SOLVAY
BANK
September 17,
2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50
Dear Mr. Feldman:
Our bank is a 87 year-old community bank with approximately $440
million in assets.
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. This would
greatly relieve the regulatory burden currently imposed on small
banks, which are now required to meet the same standards imposed
on the nation’s largest banks.
We also support the addition of a community development criterion
to the small bank examination for larger community banks, but we
believe that the FDIC should adopt its original $500 million threshold
without a community development criterion. The new community development
criterion should be applied only to banks greater than $500 million
up to $1 billion. As field examiners know, it has proven extremely
difficult for small banks to find appropriate CRA qualified investments
in their communities.
We thank you
for recognizing that “one size does not fit all” when
it comes to CRA, and we urge you to adopt your proposal.
Very truly yours,
SOLVAY BANK
Paul P. Mello, CPA
President & CEO
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