Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50
Dear Mr. Feldman:
I am pleased to have the opportunity of commenting on the FDIC’s proposal
to increase the threshold for the small bank CRA examination.
I am the Chairman and CEO of Community National Bank, an independent community
bank with assets of approximately 330 million which serves rural northern and
central Vermont with 9 offices in 4 counties. While we are a national bank for
which the FDIC is not the primary regulator, we are very interested in and supportive
of the proposal.
We just crossed the existing small bank threshold and have yet to be examined
as a “large” bank. But for two years we have been gathering data
in preparation for a “large” bank examination. Based upon what we
have seen and learned so far, I would strongly support raising the threshold
to a more meaningful figure and support the FDIC’s efforts to do so. We
have found that the data collection has been time consuming and not particularly
illuminating: they show that we make loans to small businesses and farms, which
we have been doing for 153 years. Incidentally, we have an “outstanding” rating
under the current system, so I guess the regulators have been able to determine
without difficulty that we have been meeting the credit needs of our entire community
even under the “small’ bank examination procedures. I don’t
see the “large” bank procedures as an improvement for a small, rural
bank like ours.
One aspect of the proposal that I worry about is the community development criterion.
While so far we have found appropriate community investments to make in our service
area, we worry that that might not always be the case. Our biggest fear is that
we be required to make investments out of our communities just to comply with
CRA. I can’t imagine that’s what anyone would want to see happen.
As a rural bank, we support the proposed expansion of the definition of “community
development” to include rural residents. Again, this will help ensure that
our deposits are put to work right here in the communities we serve.
Thank you for the opportunity to comment on this proposal.
