From: Carole Marshall [mailto:Carole.Marshall@unitybank.com]
Sent: Thursday, September 23, 2004 10:37 AM
To: Comments
Subject: Community Reinvestment : Rin number 3064-AC50
As a community
banker and compliance officer, I join my fellow community bankers
throughout
the nation in strong support of the FDIC’s
proposal to increase the asset size limit of banks eligible for the
streamlined small bank CRA examination.
The proposal will greatly alleviate unnecessary paperwork and examination
burden without weakening our commitment to reinvest in our communities.
Reinvesting in our communities is something we do everyday as a
matter of good business. My community bank could not survive if
my local community doesn’t thrive, my bank must be responsive
to community needs and promote and support community and economic
development.
We realize that the streamlined CRA exam is not an exemption from
CRA. It just doesn’t make sense and is inequitable to evaluate
a $500 million or $1 billion bank using the same exam procedures.
One of the problems with the current large bank CRA exam is that
the definition of “qualified investments” is too limited
and qualified investments can be difficult to find. Many community
banks have to invest in regional or statewide mortgage bonds or
housing bonds and these investments actually take resources away
from the bank’s local community. Community banks and communities
would be better off if the banks could truly reinvest those dollars
locally to support their own local economies and residents.
Our bank participates in many community development activities
that do not qualify for credit. It would benefit the bank and the
community by expanding the definition of “community development” so
that it includes activities that benefit all residents in addition
to low and moderate income individuals. Community bank are frequently
called upon to support economic or infrastructure development such
as school construction, revitalizing Main Street or loans that
help create needed or better paying jobs. Community Banks are required
to give grants and donations to various non-profit charitable organizations
that currently do not qualify for CRA credit. Donations for medical
assistance and research such as walks for March of Dimes, MDA,
Cancer and participating in blood bank drives should qualify. Also,
donations to schools for scholarships, Girl/boy scouts groups and
educational tours of the bank for children. Financial education
should qualify for all children and adults who request it. The
time frame for Employee volunteer work should be expanded and should
not be limited to work hours only. Our Community Bank participates
in these activities and they should not be ineligible for CRA credit
because they do not benefit only low or moderate income individuals.
The FDIC’s proposed changes to CRA are required to help alleviate
regulatory burden. Without changes such as this, more and more
community bank will find they cannot sustain independent existence
because of crushing regulatory burden. By easing regulatory burden,
it will make it easier for community bank to continue to provide
committed service to local communities that few other financial
service providers are willing to do.
