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TEXAS BANKERS ASSOCIATION
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Fax: (202) 898–3838
comments@fdic.gov
RE: Proposed Revisions to the Community Reinvestment Act Regulations
The Texas Bankers Association (“TBA”) appreciates the opportunity to
comment on the Federal Deposit Insurance Corporation’s (“FDIC”) proposal
to enlarge the number of banks and saving associations that will be
examined under the small institution Community Reinvestment Act (CRA)
examination. TBA represents the interests of more than 600 financial
institutions in the state of Texas. A sizable number of these banks are
between $250 and $1 billion in assets and would benefit from the
additional relief provided by reducing the compliance burden.
While regulatory burden weighs on financial institutions of all
sizes, it falls heaviest on community banks. The FDIC’s proposal to
reduce this burden for community banks is both timely and necessary.
This proposal is a major step towards an appropriate implementation of
the CRA and should greatly reduce regulatory burden on those
institutions newly made eligible for the small institution examination,
and TBA strongly supports this proposal.
While community banks will still be examined under CRA for their
record of helping to meet the credit needs of their communities, these
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.
We urge the FDIC Board to approve the proposed increase to $1 billion
in the size of the institutions eligible for the small bank CRA
examination. Thank you for the opportunity to present our views. If you
need additional information, please feel free to contact me at (512)
472-8388.
Sincerely,
B. Scott Daugherty
Assistant General Counsel
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