KENNEBEC SAVINGS BANK
From: Andrew E. Silsby [mailto:asilsby@kennebecsavings.com]
Sent: Thursday, October 07, 2004 3:17 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50
Andrew E. Silsby
Vice President & Senior Loan Officer
Kennebec Savings Bank
150 State Street
Augusta, ME 04330
October 7, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Robert Feldman:
As a community banker and our Bank's Senior Lender, 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. We crossed
over the
$250 million "large bank" mark a number of years ago and have found it
difficult to make all the things that we do for our communities count
toward the large bank tests. We do a lot for our communities in terms of
donation and services, yet most of that does not count under the large
bank tests. 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.
Kennebec Savings Bank is a mutual savings bank located in Augusta,
Maine. We are just under $500 million in assets and have about 75
employees serving the great Kennebec County area.
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. Many of
these big banks don't even contribute to the local high school yearbook
or sponsor the local baseball team, yet they get an outsatnding CRA
rating because they took investment dollars and put them into highly
risky venture funds solely for CRA credit. 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,
Andrew E. Silsby
207-622-5801
Vice President & Senior Loan Officer
Kennebec Savings Bank
