From: Dan Stegall [mailto:stegad@plantersbank.net]
Sent: Monday, October 04, 2004 11:08 AM
To: Comments
Subject: RIN 3064-AC50
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N. W.
Washington, D. C. 20429
Re: RIN 3064-AC50
Community Reinvestment Act (CRA)
Dear Mr. Feldman:
I am writing to comment on the FDIC's proposed changes to its CRA
regulation. I applaud the proposal to raise the definition of 'small
bank' for purposes of determining those banks eligible for the
streamlined examination standards. Arguments in favor of such a change
are compelling and I urge the FDIC to finalize its proposal at the
earliest possible time.
CRA compliance costs are disproportionately higher on community banks
that currently do not qualify for the streamlined test. We do not
possess the resources that larger banks have to address this issue. In
addition, lifting the regulatory burden will not affect the loans that
we make in the communities that we serve, including low and moderate
income areas.
Our bank, by the very nature of its business lends to all segments of
the community. It is too difficult to acquire earning assets to exclude
any segment from our lending even if it were not the right thing to do.
We prosper when our total community prospers and raising the threshold
will not reduce CRA loans, it will only reduce unnecessary paperwork and
costly red tape.
As a practical matter, our bank finds it very difficult to compete
with larger banks for qualified investments. The large bank test with
its investment component simply does not work for a bank our size.
Consistent with the FDIC's stated goal of reducing the regulatory burden
where appropriate, the CRA regulation should be amended as proposed.
Sincerely,
William D. Stegall
President and CEO
Planters Bank and Trust
