CATTARAUGUS COUNTY BANK
September 17, 2004
Mr. Robert Feldman, Executive Secretary
ATT: Comments / Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D.C. 20429
Re: Community Reinvestment, RIN number 3064-AC50; Streamlined CRA
Exam
Dear Mr. Feldman,
As a community banker, I join bankers throughout the nation in strong
support of the FDIC's proposal to increase the asset size limit of banks
eligible for the streamlined small-bank CRA examination. I also strongly
support the elimination of the separate holding company qualification.
Reinvesting in our communities is something our bank has done
everyday as a matter of good business since 1902. My bank must be
responsive the community needs and promote and support community and
economic services. I believe that this proposal will greatly alleviate
unnecessary burden and paperwork. Making the CRA exam process less
burdensome and more streamlined will allow resources to be redirected to
the community and used to make loans and provide other services.
It is important to remember that the streamlined CRA exam is not an
exemption for CRA. It is a more cost effective and efficient CRA exam.
Banks subject to the simplified CRA exam are still fully obligated to
comply with CRA. It doesn't make sense nor is it equitable to evaluate a
$500 million or $1 billion bank using the same exam procedures as for a
$100 billion or $500 billion bank.
Many community banks, especially those in rural areas like my bank,
are forced to invest in regional or statewide mortgage bonds or housing
bonds and the like to meet CRA requirements. Community banks and Main
Street America would be better off if the banks could truly reinvest
those dollars locally to support their own local economies and
residents.
For this reason, I find that the FDIC's proposed community
development requirement for banks between $250 million and $1 billion is
more flexible and more appropriate than the large bank investment test.
The proposal would allow for keeping the bank's strategies focused and
meeting the local community's needs.
The FDIC's proposed changes to CRA are needed to help alleviate
regulatory burden. By easing the regulatory burden, it will make it
easier for community banks like mine to continue to provide committed
service to local communities that few other financial service providers
are willing to do.
Thank you for your consideration and anticipated support.
Sincerely,
Salvatore Marranca
President & CEO
Cattaraugus County Bank
Franklinville, NY
