From: Bob Wheeler [mailto:bobw@firstbank-corp.com]
Sent: Saturday, September 18, 2004 10:28 AM
To: Comments
Cc: psmith@aba.com
Subject: Small bank CRA Exemption
Dear Mr. Feldman,
My name is Bob Wheeler, and I am a Senior Vice President at Firstbank in Mt.
Pleasant, Michigan. We are a community bank and are currently tested under
the small bank CRA examination. I am in support of passage of RIN No. 3064-AC50,
the extension of the small bank exception up to $ 1 Billion.
Most community banks are composed of people within the community who take pride
in being a part of that community. Our primary focus is service to that community,
both lending, deposit and our own personal time. There is a huge difference
between these community banks and the mega bank, yet the distinction rarely
benefits us. We have the same regulatory burden that the large banks have,
yet without the resources. Every time the CRA result are posted, I notice the
vast majority of the community banks receive a Satisfactory or Outstanding
rating. This the perfect bill to see that our community banks, the lifeblood
of our rural areas, are given the credit they deserve in minimizing the regulatory
burden.
I also oppose the concept of making the Community Development test separate
from the banks overall CRA evaluation. To do this would continue to add to
the regulatory burden of the small community bank.
Thanks for listening to me and I hope you will consider my comments.
Bob Wheeler
