|
FIRST BANK & TRUST CO.
Federal Deposit Insurance Corporation
Robert E. Feldman, Executive Secretary
Attn: Comments
550 17th Street, NW
Washington, DC 20429
12 CFR Part 345
RIN 3064-AC50
I am writing in response to the notice of proposed rulemaking of the
CRA, which includes an amendment to reduce the regulatory burden
consistent with the current definition of a “large institution” by
increasing the definition of a “small institution” to that being an
institution with total assets of under $500 million. Our institution has
$267 million in total assets as of December 31, 2003. We reached $250
million in total assets in September of 2001. Under current definitions,
we are now a CRA “large institution”. Our main office is in Duncan,
Oklahoma and we have several other banking centers in Healdton, Ardmore,
and Norman, Oklahoma as well.
Being surrounded by larger statewide banks in all of our markets such
as BancFirst ($2.7 billion); Arvest Bank ($7 billion); and Local
Oklahoma Bank ($2.9 billion) we feel the proposed move from $250 million
to $500 million does not adequately provide relief to the banks caught
in the small to large bank transition. A threshold increase to $1
billion would be more adequate. Banks under $1 billion are generally
struggling due to manpower and opportunities in their assessment areas
to perform the tasks required of the CRA. The overly burdensome
reporting requirements are overwhelming for a smaller bank that does not
have the budget or personnel to comply. Additionally, finding
opportunities for community development lending, investments, or
services is quite a task when competing with billion dollar banks that
if there are not opportunities available then they have the funds to
create opportunities of their own.
If a bank intends to grow into a billion + dollar bank then it will
have the opportunity to meet the large bank test and at that time will
be on a level playing field. However, for banks that are under one
billion in assets and are stable and in a non-growth environment, it is
unjust to expect them to be measured and pitted against billion + dollar
institutions.
I commend the regulatory agencies to consider this change to the CRA
and I understand that they must weigh comments from financial
institutions against those from community organizations who are against
the proposed changes. However, financial institutions have been closely
scrutinized and highly regulated in regards to the abusive lending
practices which the CRA was set forth to regulate. The abuses that the
CRA attempts to discourage might actually be more prevalent today in
non-bank institutions such as credit unions and finance or insurance
companies that have in recent years expanded to include a much larger
base of customers and offering very traditional loan products. These
non-bank institutions are making every effort to meet the credit needs
of the very same communities in which our financial institution operates
and can therefore assuage consumers into borrowing with them and not
being subject to such regulations as the CRA they can operate under any
such credit terms as they see appropriate.
This financial institution has received three previous “outstanding”
CRA ratings and we are preparing for our first large bank examination in
2005. We have always had a strong commitment to fulfill the requirements
of the CRA and have taken it very seriously. This will not change even
if the threshold changes and we move back into small bank status. We
will continue to provide services and assistance throughout our
assessment areas, provide innovative and flexible credit programs, and
give back to all areas of our communities through investments and
donations.
Thank you for the opportunity to comment on this notice of proposed
rulemaking. Should you have any questions, please contact me at
580-255-1810.
Sincerely,
Shannon Contreras
CRA Administrator
First Bank & Trust Co.
P.O. Box 580
Duncan, OK 73534
580-255-1810
580-255-3329 Fax
|
