BAY STATE SAVINGS BANK
From: Robert Duquette [mailto:rduquette@baystatesavings.com]
Sent: Friday, September 17, 2004 3:44 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50
Robert Duquette
Senior VP &CFO
Bay State Savings Bank
28 Franklin Street
Worcester, MA 01608
September 17, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Robert Feldman:
As a community banker, I am pleased to comment in support of the
proposal issued by the FDIC that would amend the definition of a small
institution to be a bank that is under $1 billion in assets. I believe
that this change will provide much needed regulatory burden relief for
me and other community bankers. It seems that every week there is a new
or additional regulation with which we must comply. This is one example
of regulatory burden relief that will really make a difference. I would
much rather use the limited resources available to my bank to serve my
community than to collect and maintain data and documents to prove to
examiners that I am meeting the needs of my community.
Bay State Savings Bank is a $260 million financial instituion which
serves communities in Central Massachusetts.
Compliance with the Community Reinvestment Act is something we take
very seriously at our bank. We don’t just believe it is the right thing
to do; we believe it is the right business thing to do. No community
bank can survive and compete without meeting the needs of its customers
and communities. We believe in our community and in our customers and
want to work with them to provide products and services that best meet
their credit needs. We do not need a complicated examination process to
show that we are complying with the law.
It is absurd to think that a bank thousands of times larger than my
own community bank should be examined using the same procedures. I
strongly urge you to amend the definition of a small bank for CRA
purposes to be an institution with less than $1 billion in assets,
regardless of whether the bank is part of a holding company. This is a
good proposal and is the right thing to do.
Thank you for considering my views.
Sincerely,
Robert B. Duquette
Senior VP &CFO
Bay State Savings Bank
