SOUTHWEST BANK
October 5, 2004
Public Information Room
Office of the Comptroller of the Currency
250 E Street, SW
Mailstop 1-5
Washington, DC 20219
Fax: 202-874-4448
e-mail: regs.comments@occ.treas.gov
Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Website: http://www.fdic.gov/
e-mail: comments@fdic.gov
Ms. Jennifer J. Johnson, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551
Fax: 202-452-3819
e-mail: regs.comments@federalreserve.gov
Regulation Comments
Chief Counsel's Office
Office of Thrift Supervision
1700 G Street, NW
Washington, DC 20552
Fax: 202-906-6518
e-mail: regs.comments@ots.treas.gov
Re: Oxley’s Lead in Charge for Community Reinvestment Act Reform
Dear Sir or Madam:
I am extremely thankful to House Financial Services Committee Chairman
Mike Oxley (R-OH) and the 20 other Republicans* who recently told FDIC
Chairman Donald Powell, in a September 22, 2004 letter, that they
support the agency’s proposed changes to CRA regulations that would
raise the asset size limit for streamlined examinations to $1 billion.
As stated in the letter, “The FDIC’s proposal will permit small
institutions to focus their time and resources to the communities they
serve rather than complying with burdensome regulatory requirements.”
Additionally, the letter went on to say “We would support the FDIC’s
community development test as proposed so long as this test would
provide banks with more flexibility to deal with CRA regulations in a
cost-effective way while not imposing any new regulatory burdens and
costs.”
As a community banker, I couldn’t agree more with the sentiments,
statements and facts of these two very succinct statements! It would
appear to me that these Members truly do understand the excessive cost
and time constraints small community banks would disproportionately face
if they were to be subjected to the same CRA requirements as the large
multi-million dollar mega-banks.
The reporting and tracking requirements for large banks versus small
banks are out of proportion in relation to the benefit to be gained. The
decision to increase the threshold for small banks should be supported
by all the Regulatory Agencies, and all members of the House, Senate and
Congress as well.
*Additional thanks also go to: Richard Baker (LA), Spencer Bachus
(AL), Robert Ney (OH), Ed Royce (CA), Ron Paul (TX), Paul Gillmor (OH),
Jim Ryun (KS), Walter Jones (NC), Doug Ose (CA), Tom Feeney (FL), Jeb
Hensarling (TX), Scott Garrett (NJ), Ginny Brown-Waite (FL), J. Gresham
Barrett (SC), Shelly Moore Capito (WV), W. Todd Akin (MO), Jim Gerlach
(PA), C. L “Butch” Otter (ID), Pete Sessions (TX) and Roscoe Bartlett
(MD).
Thank you in advance for letting me share my thoughts with you on
this topic.
Sincerely yours,
Bill Mansfield
Vice President \ Credit Administration
