Farmers & Merchants Bank & Trust
From: Norma Dahms
Sent: Wednesday, March 24, 2004 5:04 PM
To: Comments
Subject: Comments on CRA Revisions
Norma Dahms
221 Jefferson Street
Donnellson, Iowa 52601
March 24, 2004
Dear FDIC:
I am writing
on behalf of Farmers & Merchants Bank & Trust,
a
state-chartered bank located in Burlington, Iowa. Our customer base
is
primarily agricultural and moderate income households with lending
activities and are broad based and include commercial, consumer and
real
estate lending. Our current asset size is $234,000,000 with a loan
portfolio of $83,000,000. We applaud and appreciate the proposed
amendments to the Community Reinvestment Act being made by the Office
of
Comptroller of the Currency, Federal Reserve Board, Federal Deposit
Insurance Corporation and Office of Thrift Supervision, “the
Agencies.”
We also appreciate the Agencies’ recognition and understanding
of the
challenges faced by community banks in meeting the requirements of
the
ever-growing number of compliance regulations.
The reporting requirements under the large bank CRA exam process
are
staggering for a small bank. Under the current rules, due to our
state’s
rural population an institution may not be a HMDA reporter because
it is
not located in a MSA, could still be subject to the large bank CRA
test
and data collection due solely to having assets in excess of $250
million.
While community banks still must comply with the general requirements of
CRA, this asset-size increase will eliminate some of the most problematic
and burdensome elements of the current CRA regulation.
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 streamlined
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. The change merely reduces the reporting requirements and
costs
for small bank, freeing up more time and money that can be better
spent in
service to the community the bank is located.
Thank you for directing your attention to this very important area
of
regulation.
Sincerely,
Norma J. Dahms
Farmers & Merchants Bank & Trust
Burlington, IA
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