KENNEBEC SAVINGS BANK
From: George Diplock [mailto:gdiplock@kennebecsavings.com]
Sent: Friday, October 08, 2004 2:48 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50
George Diplock
AVP
Kennebec Savings Bank
PO Box 50
Augusta, Me 04332
October 8, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Robert Feldman:
As a community banker, 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. 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.
I am the CRA Officier for our bank, which has three offices, all
located in Kennebec County, Maine. We are around $390 million in asset
size, with 85 employees, and do much in our community that we do not get
CRA credit for. Our focus will not change regardless of the CRA Act
requirements. The larger banks seem to invest in activities that meet
their CRA
requirements, but not necessarily provide the most benifit to local
lower income citizens.
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. 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,
George W. Diplock Jr.
207-622-5801
AVP
Kennebec Savings Bank
