From: Fred Drake [mailto:fdrake@hbtbank.com]
Sent: Monday, September 20, 2004 4:55 PM
To: Comments
Subject: RIN 3064-AC50
I strongly support raising the 'small bank' asset size threshhold
to $1
billion.
Our bank has been subject to 'the large bank' CRA exams for several
years now. I can attest that there has been
no good result of this process, only more time and paperwork.
Our bank has long been a strong, local community bank,virtually
all
loans made in our local areas. We should not have to prove, by
documentation or extraordinary efforts, that this is the case. Any
observer could look and see quickly that we are locally focused bank.
The CRA legislation has ballooned out of proportion. There are clearly
banks (though very few in number) that are not really community
oriented. The rest of the industry has been punished, by new
regulations and documentation requirements.
The proposed regulation shows ways that community banks can seek
an
'outstanding' rating. Why not find a very simple way, low documentation
way that community banks can achieve a 'satisfactory' rating?
Sincerely,
Fred L. Drake,
President & CEO
Heartland Bank & Trust Co.
PO Box 67
Bloomington, IL
