Robert E. Feldman, Executive Secretary
Attention: Commercial/Legal ESS
FDIC
550 17th Street NW
Washington D.C. 20429
Dear Mr. Feldman,
As a community
banker, I am writing in support of the proposal to raise the asset
limit
for the “small bank” streamlined
CRA examination. In the total banking picture, we are definitely
still a “small” bank even as we edge into the large bank
category according to current regulations. Under those regulations,
we are about to become subject to a very substantial increase in
regulatory burden as the result of a very limited advance in our
financial position. The strain on limited resources, especially at
a time when other regulatory demands continue to expand greatly,
would be considerable. While viewing the proposal favorably, we do
oppose the addition of new community development criterion, and for
the same reasons. Raising the limit allows us to continue to perform
as we have been. Adding the community development section diminishes
our ability to do that by creating a significant burden which is
not a reflection of any increased opportunity to meet new standards.
We have always taken pride in our CRA performance which has resulted
in consistent Outstanding ratings and we have been gratified by the
good business opportunities it has provided. The suggestion that
our community would be less well served by us through a proposal
that only seeks to keep pace with the evolving banking environment
is not creditable.
Thank you for the opportunity to comment.
Sincerely,
Thomas E. Unsworth
Senior Vice President, Mortgages
CRA Officer
