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TAYLOR BANK
August 26, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
E-Mail: comments@fdic.gov
RE: Notice of Proposed Rulemaking on CRA RIN No.: 3064-XXXX.
Dear Mr. Feldman:
We strongly endorse the Federal Deposit Insurance Corporation's
proposal to increase the asset size of banks eligible for the small bank
CRA examination to $1 billion. Our bank's regulatory burden has
increased greatly over the past few years with the passage of such laws
as Gramm-Leach-Bliley Act, the USA PATRIOT Act, and the FACT Act, while
we understand the need for the myriad of banking regulations, we find
complying with them extremely burdensome. Changing the asset threshold
to $1 billion will relieve us of an unnecessary regulatory burden,
leaving more time for our employees to meet the credit needs of our
community.
Our current asset size is $416 million. We would like to emphasize
that banks our size are already at a competitive disadvantage to credit
unions and other financial entities that do not have the same regulatory
burden as community banks, especially in areas like Community
Reinvestment, incurring significant costs in CRA compliance that mane of
our competitors (e.g., credit unions) are not.
Also, as an institution
that has recently become a "Large Bank" under
the definitions of Part 345, we have found that banks should be
evaluated against their peers, not banks hundreds of times their size.
Large banks with assets in the hundreds of billions of dollars blanket
the country. It is not fair to rate a community bank using the same
CRA
examination.
Additionally, we are pleased that the FDIC has proposed a broad
definition of community development to include all activities that
benefit not just low- and moderate-income residents but also residents
of rural areas.
In summary, we believe it is very important for the FDIC to do all
that it can to minimize the burdens associated with CRA. We appreciate
the opportunity to comment on this important proposal.
Sincerely,
Reese Cropper, Jr.,
Chairman & CEO
Calvin B. Taylor Banking Co.
24 N Main
Berlin, MD 21811 |
