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POLONIA BANK
From: Kenneth Maliszewski [mailto:kmaliszewski@poloniabank.com]
Sent: Wednesday, October 06, 2004 10:08 AM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50
Kenneth Maliszewski
Vice President
Polonia Bank
3993 Huntingdon Pike
Huntingdon Valley, PA 19006
October 6, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Robert Feldman:
As a community banker, I am pleased to comment in support of the
proposal issued by the FDIC that would amend the definition of a small
institution to be a bank that is under $1 billion in assets. I believe
that this change will provide much needed regulatory burden relief for
me and other community bankers. It seems that every week there is a new
or additional
regulation with which we must comply. This is one example of regulatory
burden relief that will really make a difference. I would much rather
use the limited resources available to my bank to serve my community
than to collect and maintain data and documents to prove to examiners
that I am meeting the needs of my community.
Polonia Bank has served its community since 1923 and will continue to
do so in the future. We and a small mutual financial institution of 185
Million in assets located in Philadelphia area. We have 4 offices in the
city and 1 office just outside the city limits that are a integeral part
of the neighborhoods we serve. Polonia has apox. 45 employees that work
as well as live in these areas.
Compliance with the Community Reinvestment Act is something we take
very seriously at our bank. We don’t just believe it is the right thing
to do; we believe it is the right business thing to do. No community
bank can survive and compete without meeting the needs of its customers
and communities. We believe in our community and in our customers and
want to work with them to provide products and services that best meet
their credit needs. We do not need a complicated examination process to
show that we are complying with the law.
It is absurd to think that a bank thousands of times larger than my
own community bank should be examined using the same procedures. I
strongly urge you to amend the definition of a small bank for CRA
purposes to be an institution with less than $1 billion in assets,
regardless of whether the bank is part of a holding company. This is a
good proposal and is the right thing to do.
Thank you for considering my views.
Sincerely,
Kenneth J. Maliszewki V.P.
215-938-8800
Vice President
Polonia Bank |
