PEOPLES BANK
October 7, 2004
Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, D.C. 20429
RE: Community Reinvestment Act (CRA) Proposal
RIN number 3064-AC50
Peoples Bank is a $580 million bank with 20 offices located in
predominately small, rural communities in Whatcom, Skagit, King, Chelan
and Douglas County in Washington State.
I support the FDIC’s proposal to increase the asset size limit of
banks eligible for the streamlined small bank CRA examination. I also
support the elimination of the separate holding company qualification.
This would be a positive change for small banks who are currently
burdened with the CRA reporting requirements of a large bank.
In addition, I strongly support expanding the definition of community
development. As a community bank, we would not be in business if our
local communities were not adequately being served. Expanding the
definition of community development to encompass a broader range of
activities will provide greater community development opportunities for
our bank. It would allow banks to pursue activities that not only meet
community needs, but coincide with the bank’s strategic plan.
The success of Peoples Bank is a result of promoting and supporting
economic development in the community. Raising the definition from $250
million to $1 billion will not change how we operate. Instead, it will
lessen the regulatory burden and allow resources to be directed towards
community development rather than reporting.
Thank you for considering my comments.
Sincerely,
Lennis Camfield
CRA Officer
Peoples Bank (certificate #6158)
