CITIZENS NATIONAL BANK OF EVANS CITY, PA
From: Don Shamey [mailto:dshamey@thebank.com]
Sent: Wednesday, October 06, 2004 2:57 PM
To: Comments
Subject: RIN Number 3064-AC50
Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
Mr. Feldman
I respectfully comment on the FDIC's proposal to redefine a small
institution from a threshold of $250 million to $1 billion for CRA
purposes. Being the CEO of a $450 million community bank, I fully
support this proposal.
First, it is our mission to support all aspects of our community. We
always have and always will. It's simply the way we do business.
Second, considering today's financial landscape it is inappropriate
to consider an institution over $250 million as "large" in whatever
context it be measured.
Third, it is very difficult for banks under $1 billion to comply with
the investment test as it is currently measured. Why have a standard
that is virtually impossible for smaller institutions to meet?
Fourth, community banks are drowning in regulatory compliance. Every
bit of regulatory relief is welcomed and this proposal would be with
open arms.
Finally, I appreciate the concern of the community activist groups
with this change. However, upon a more thorough analysis, I'm sure they
would find that banks under $1 billion are not typically the
institutions that need CRA regulation. I refer back to my first point.
I'm sure that you've heard all of this before. The reason is that
these are valid points in support of the FDIC's proposal. I commend your
agency for its forthright stance on this issue.
Respectfully
Donald S. Shamey
CEO
Citizens National Bank of Evans City, PA
