GRABILL BANK
September 2, 2004
Robert E. Feldman, Executive Secretary
Attn: Comments/Legal ESS
Federal Deposit Insurance Corp.
550 17th St., NW
Washington, DC 20429
RE: FDIC — RIN
3064-AC50
Dear Mr. Feldman:
We appreciate your requesting our input concerning proposed changes
in the Community Reinvestment Act. As a bank that is $500,000,000
in size serving a small community, we would heartily agree that increasing
the threshold to $1 billion in assets for a large bank would be a
proper and good thing to do. With the inflation of numbers over time
and the fact that many community banks have moved more into mortgage
and commercial lending, we believe the threshold numbers should be
$1,000,000,000. While captive financial companies and to some extent,
credit unions, have taken much of the consumer business from community
banks, the fact is that community banks still provide a major portion.of
home loans to our community and continue to be the life blood of
small communities. One reason we feel that detailed CRA requirements
are not needed for community banks is because the HMDA reporting
requirements accurately reflect to a large extent how faithful a
community bank is serving its own neighborhood. Our own bank has
invested over 12,000 volunteer hours of service by our staff and
Board of Directors to our community as well as contributed 3.50%
of our net profits in the form of charitable contributions. Many
of the local chambers and economic development boards are made up
of bank officers because of our closeness to the community through
local ownership, staffing and service. We feel community banks do
a very good job of serving those that reside in our CRA designated
area.
You had asked for a comment concerning whether a. community development
test should be devised for community banks as well as a lending test.
We do not oppose such an idea. However, it would be very important
to involve leaders from small communities and community bank officers
in devising such a test.
Thank for your input.
Sincerely,
Brent L. Clifton
Vice Chairman
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