September 17, 2004
Mr. Robert E. Feldman Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 170i Street, NW Washington, DC 20429
RE: RIN Number 3064-AC50 Dear Mr. Feldman:
Our bank is a 112 year-old community bank with approximately $390
million in assets.
We strongly support the FDIC's proposal to raise the threshold for
the streamlined small bank CRA examination to $1 billion. 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 $1 trillion 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,
John W. Borland President & CEO
Orange County Trust Company
Middletown, NY
