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Farmers State Bank
April 8, 2004
Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
500 17th Street NW
Washington, DC 20429
RE: Community Reinvestment Act Proposal
To whom it may concern:
I am a community banker working for a financial institution located
in Marion, Iowa. I appreciate the opportunity to comment on the proposed
amendments to the Community Reinvestment Act (CRA).
While I support your proposal to increase the asset size for banks
eligible to be examined under the CRA small bank test to $500 million, I
urge you to consider increasing that threshold to $1 billion. Our
financial institution is quickly growing towards the $500 million mark,
and I do not feel that with seven locations we are comparable to banks
with several hundred locations and billions of dollars in assets. It is
extremely difficult for a bank of our size to compete with
billion-dollar institutions for qualified investments that meet the
requirements under large bank CRA. The larger institutions have the
money, manpower and technology to beat us every time. Too many times the
effort we put forth to meet investment goals goes unrecognized, as it is
overshadowed by the performances of our billion-dollar “peers”.
I also support the elimination of the bank holding company asset size
threshold. Many banks maintain their own charter, management and
operational processes when purchased by a large holding company. They
“inherit” the regulatory requirements of the holding company but do not
always benefit from the holding company’s resources for complying with
these requirements.
Increasing the size of banks eligible for the small bank CRA exam
does not relieve banks from CRA responsibilities. The growth and
survival of the bank is intertwined with the growth and survival of the
community. Working at a family owned, community bank, my attitude
towards supporting the community in which I call home would remain
unchanged. The bank would merely have a reduction in reporting
requirements and costs, freeing up more time and money that could be
better spent in the development of the community.
Today’s community banks are drowning in regulatory red tape,
utilizing valuable resources to meet regulatory compliance mandates that
could be put to much better use for economic and development purposes in
the communities in which we live and work. Thank you for recognizing
this and proposing the changes to the Community Reinvestment Act. If you
have any questions in regards to these comments, please feel free to
contact me.
Sincerely,
Debby A. Roth
Vice President REO
Farmers State Bank
1240 8th Avenue
Marion, IA 52302
319-377-4891 X1080
debroth@fsbmail.net |
