Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Hand Delivered
Re: RIN Number 3064-AC50:
Dear Mr. Feldman:
We strongly support the FDIC's proposal to raise the threshold for
the streamlined small bank CRA examination to $1 billion without regard
to the size of the bank's holding company. This would greatly relieve
the regulatory burden imposed on small banks under the current
regulation, which are required to meet the standards imposed on the
nation's largest $1 trillion banks. Community banks would still be
required to help meet the credit needs of their entire communities and
would continue to be so evaluated by their regulator.
We 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 (CD) criterion. The new CD criterion should be
applied only to banks greater than $500 million up to $1 billion.
Community banks up to $500 million now hold about the same percent of
overall industry assets as community banks up to $250 million did a
decade ago when the revised CRA regulations were adopted, so this
adjustment in the CRA threshold is appropriate. As FDIC examiners know,
it has proven extremely difficult for small banks, especially those in
rural areas, to find appropriate CRA qualified investments in their
communities. Many small banks have had to make regional or statewide
investments that are extremely unlikely to ever benefit the banks' own
communities. This result certainly was not intended by Congress when it
enacted CRA.
Sincerely yours,
Lloyd I. Hendricks
President & CEO
South Carolina Bankers Association
2009 Park Street
Columbia, SC 29202
