EMPORIA STATE BANK & TRUST COMPANY
From: Jim Wayman [mailto:jimw@esbtrust.com]
Sent: Friday, September 17, 2004 3:37 PM
To: Comments
Subject: CRA Small Bank Threshold
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:
I am associated with a small community bank less than $500 million in
size, and 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. The streamlined
examination procedures have been a blessing to our bank.
We are very active in our community, and we were spending countless
hours documenting what we do. The problem was that we were told that due
to the lack of low-income areas in our community, we could not qualify
for the highest rating no matter how hard we tried. If we were a larger
bank in our community and did not have the streamlined examination
procedures available to us, it would be a waste of time. Trying to meet
the same requirements of the largest banks in our country does not make
sense in a community of our size and demographics.
FDIC’s proposal to change the definition of “community development”
from only focusing on low- and moderate-income area residents to
including rural residents would make a lot of sense for us in our
community as well.
The flexibility needs to remain for community banks.
Jim Wayman, President
Emporia State Bank & Trust Company
PO Box 807
Emporia, KS 66801
