LEGACY
BANK
From: Ed Clouse [mailto:EdC@legacybank.com]
Sent: Tuesday, March 30, 2004 9:08 AM
To: Comments
Cc: Steve Carmack
Subject: EGRPRA
March 30, 2004
Mr. Robert E Feldman
Executive Secretary
Federal Deposit Insurance Corporation
550-17th St., NW
Washington, DC 20429
Dear Mr. Feldman:
Being able to
voice one’s opinion is the foundation on which
our great nation is built. We, as bankers, appreciate the opportunity
to do so here. Legacy Bank has been in existence for over 100 years.
As we’ve gained success and continued our growth, which is
the American way, it seems we meet more and more regulatory burden
at every stage. We are certainly not opposed to the protection of
consumers, our customers. We are, however, quite concerned when that “protection” becomes
so burdensome it prohibits our ability to provide the highest quality
service possible. It is my belief that we are at that point. Sir,
some of these regulations simply don’t make sense. I’ll
try to explain.
Ø CRA and HMDA-We’ve been important parts of the communities
we serve for decades. If we aren’t included in the growth or
our community, we will perish. No one is more involved in the well
being of a community than a local bank. The reporting requirements
for CRA and HMDA are onerous at best. The threshold on report for
banks under these two regulations should be raised to at least $1
Billion dollars. I would think $2 Billion would be more appropriate.
Ø 12 CFR 226 (REG Z) TRUTH IN LENDING 3 day Right of Recession.
We probably get as many complaints from customers about this regulation
as all the rest put together. Our customers must go through an extensive
process, due to a number of other regulations, in order to even get
to the closing of a real estate loan. They are aware of what they
are doing and don’t need protection from the government and
don’t need to be delayed further their loan proceeds.
Ø FLOOD HAZARD INSURANCE-Shouldn’t
the value of the land be included in the amount of insurance required?
Ø 12 CFR 202 (REG B)-EQUAL CREDIT OPPORTUNITY-If customers
are asked to disclose information and do not wish to do so, why must
our loan officers guess at the ethnicity of the potential borrower?
If they don’t want the information provided, why should we
be forced to go against their wishes?
There are certainly
some I’ve missed but this is a good sampling
of some changes which could be made that would allow us to provide
better service to our customers.
We look forward to working with you for many years to come.
Respectfully
Edward O Clouse
Regional President
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