COMMUNITY BANK AND TRUST
From: DHoward000@aol.com [mailto:DHoward000@aol.com]
Sent: Friday, October 08, 2004 3:03 PM
To: Comments; psmith@aba.com
Subject: RIN No. 3064-AC50
Rye: RIN Number 3064-AC50: FDIC Proposed Increase in Threshold
for the Small Bank CRA Streamlined Examination
I am Duncan Howard, a director of the Community Bank and Trust in
Waco, Texas, which has assets of $270,000,000. I strongly support the
FDIC’s proposal to raise the threshold for the streamlined small bank
CRA examination to $1
billion without regard to the size of the bank’s holding company. This
would ease the current regulatory requirement placed on small banks that
are required to meet the standards imposed on the nation’s largest $1
trillion banks.
Community banks would, of course, remain required to assist the credit
needs of their entire communities and would be so evaluated by their
regulator.
In addition, I support including of a community development criterion
in the small bank examination for larger community banks. I feel the
FDIC should adopt its original $500 million threshold without a
Community Development criterion and that the new Community Development
criterion should be applied only to banks greater than $500 million up
to $1 billion. As FDIC examiners realize, it is difficult for small
banks in rural communities, to locate regional or statewide investments
that will benefit the bank’s own community, as intended by Congress
I and certainly, I oppose making the CD criterion a separate test
from the banks overall CRA evaluation. This would create an undesirable
impression that CD lending is a different lending in the community. A
combination of CD lending and services to assist community lending would
enhance the small bank CRA streamlined examination,
I appreciate and support the FDIC’s proposal to change the definition
of Community Development from only low level and moderate income
residents to include rural residents. This will discourage small rural
banks from investing in regional housing bonds for an urban area
separate from the bank’s community.
Sincerely,
Duncan Howard
