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via e-mail
WESTERN SIERRA BANK
March 10, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20551
Docket No. R-1181
comments@fdic.gov
RE: COMMUNITY REINVESTMENT ACT REGULATIONS
Dear Sir or Madam:
As a community banker, I strongly endorse the federal bank
regulators' proposal to increase the asset size of banks eligible for
the small bank streamlined Community Reinvestment Act (CRA) examination
from $250 million to $500 million and elimination of the holding company
size limit (currently $1 billion). This proposal will greatly reduce
regulatory burden. I am the President/Chief Executive Officer of Western
Sierra Bank, a $450,000,000 asset bank located in Cameron Park,
California.
The small bank CRA examination process was an excellent innovation.
As a community banker, I applaud the agencies for recognizing that it is
time to expand this critical burden reduction benefit to larger
community banks. At this critical time for the economy, this will allow
more community banks to focus on what they do best - fueling America's
local economies. When a bank must comply with the requirements of the
large bank CRA evaluation process, the costs and burdens increase
dramatically. And the resources devoted to CRA compliance are resources
not available for meeting the credit demands of the community. Changing
the law would greatly reduce compliance costs in my bank. Adjusting the
asset size limit also more accurately reflects significant changes and
consolidation within the banking industry in the last 10 years. To be
fair, banks should be evaluated against their peers, not banks hundreds
of time their size. The proposed change recognizes that it's not right
to assess the CRA performance of a $500 million bank or a $1 billion
bank with same exam procedures used for a $500 billion bank. Large banks
not stretch from coast-to-coast with assets in the hundreds of billions
of dollars. It is not fair to rate a community bank using the same CRA
examination. And, while the proposed increase is a good first step, the
size of banks eligible for the small-bank streamlined CRA examination
should be increased to $2 billion, or at a minimum, $1 billion.
Ironically, community activists seem oblivious to the costs and
burdens. And yet, they object to bank mergers that remove the local bank
from the community. This is contradictory. If community groups want to
keep the local banks in the community where they have better access to
decision-makers, they must recognize that regulatory burdens are
strangling smaller institutions and forcing them to consider selling to
larger institutions that can better manage the burdens.
Increasing the size of banks eligible for the small-bank streamlined
CRA examination does not relieve banks from CRA Responsibilities. Since
the survival of many community banks is closely intertwined with the
success and viability of their communities, the increase will merely
eliminate some of the most burdensome requirements.
In summary, I believe that increasing the asset-size of banks
eligible for the small bank streamlined CRA examination process is an
important first step to reducing regulatory burden. I also support
eliminating the separate holding company qualification for the
streamlined examination, since it places small community banks that are
part of a larger holding company at a disadvantage to their peers. While
community banks still must comply with the general requirements of CRA,
this change will eliminate some of the most problematic and burdensome
elements of the current CRA regulation from community banks that are
drowning in regulatory red-tape. I also urge the agencies to seriously
consider raising and size of banks eligible for the streamlined
examination to $2 billion or, at least, $1 billion in assets to better
reflect the current demographics of the banking industry.
Sincerely,
Kirk N. Dowdell
President/CEO
Western Sierra Bank
Cameron Park, CA
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