FDIC Federal Register Citations

 
BANK OF SOUTHSIDE VIRGINIA

From: Peter Clements [mailto:peter.clements@bsvnet.com]
Sent: Friday, March 19, 2004 5:56 PM
To: Comments
Subject: Proposal to raise small bank CRA evaluation to 500 million

Ladies and Gentlemen,

As one of the Banks who has been advocating this position ever since we crossed the 250 million dollar size threshold I would like to support the proposal that is being considered by the FFIEC. Our bank has been rated "outstanding' both under the old guidelines and the new ones although it took one full cycle to be able to meet the higher documentation requirements once we surpassed the "large bank" limit. It was not an easy task and was accomplished only with the assistance of the CRA Examination team that helped us through the maze of information required.

Being a Community Banker headquartered in a town of about 300 I find it incredible that we operate under the same rules as Citigroup or The Bank of America. I realize that the proposal will probably not apply to my institution very much longer as we are nearing 450 million in Assets but I do think it is long overdue. The vast majority of banking assets will still be covered but the small institutions without the large staff to document CRA activities will have some relief. My suggestion would be to make the threshold 1 billion dollars and index it to inflation so that this debate will not have to take place any more than once. Thank you for your proposal and consideration. It is much appreciated and needed.

Sincerely,

Peter Clements
President & CEO
The Bank of Southside Virginia