FDIC Federal Register Citations
From: Dorothy Bushnell [mailto:dbushnell@csbbanking.net]
Sent: Monday, October 18, 2004 3:46 PM
To: Comments
Subject: RIN number3064-AC50
October 13, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments/Legal #ESS
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429
Dear Mr. Feldman:
As you requested, I would like to comment on the proposed amendments
to the
Community Reinvestment Act.
The proposed amendment to change the definition of a small institution
to
mean an institution with total assets of up to $1 billion, would certainly
relieve our institution of a very burdensome task. Our institution has
had
to deal with the increased regulatory burden of data collection and
reporting on its small business, small farm and community development
loans.
These are community banks that make the majority of their loans inside
their
assessment areas.
Also, under the large bank CRA examination process, the investment test
is
difficult for a community bank to attain a satisfactory rating. With
regional and national banks competing for suitable investments in our
market, they have an unfair advantage due to their size. The larger banks
will spend whatever it takes to get those investments, making it harder
for
the smaller institutions to get a satisfactory rating at exam time.
We are in favor of changing the definition of a small institution to
one
with total assets of up to $1 billion without regard to the holding company
assets.
Thank you for considering this matter.
Sincerely,
Dorothy Bushnell
VP - Branch Manager
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