| Branch Banking & Trust
Co.
March 31, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments, Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429
Re: Notice of Proposed Rulemaking regarding the Community
Reinvestment Act.
Dear Mr. Feldman:
Branch Banking and Trust (BB&T) appreciates the opportunity to
comment on the joint interagency notice of proposed rulemaking regarding
the Community Reinvestment Act (CRA) Regulation.
BB&T Corporation, headquartered in Winston-Salem, North Carolina,
operates more than 1,350 banking offices in the Carolinas, Virginia,
Maryland, West Virginia, Kentucky, Tennessee, Georgia, Florida, Alabama,
Indiana and Washington, D.C. Currently, BB&T Corp. is the nation's 13th
largest financial holding company with over $90 billion in assets.
The following comments address the proposed revisions for (1)
adjusting the definition of "small institution" and (2) considering
violations of other laws when assigning the CRA rating.
1) Small Institution
Proposal to raise the small institution asset threshold to $500 million,
without reference to holding company assets.
Although this revision will not directly impact BB&T, we agree that
redefining "small institution" to include institutions with total assets
up to $500 million will improve the effectiveness and efficiency of the
regulatory process.
2) Credit Terms and Practices –
a. Proposal to clarify that an institution's CRA evaluation will be
adversely affected by evidence of discriminatory, other illegal and
abusive credit practice by any affiliate, if any loans of that affiliate
have been considered in the CRA evaluation pursuant to 22©(1) and (2).
BB&T supports and maintains high standards when providing credit to
customers and complying with all lending laws. However, we do not agree
with adding other banking regulations to CRA. Specifically, the proposal
to assess "...discriminatory, other illegal or abusive credit
practices..." i.e. predatory lending as a part of the bank's CRA
Examination. Although BB&T strongly rejects this type of lending, we
believe the CRA regulation is not the appropriate means to address this
issue. When you consider the numerous definitions of predatory lending
along with the proposal to include affiliate lending, these additions
may ultimately decrease the effectiveness of the regulation by
increasing the complexity and cost of compliance.
BB&T appreciates your consideration on these proposed revisions to
the CRA regulations. Should you have questions regarding our comments,
please contact me at 704-954-1100.
Respectfully,
Chester A. Williams, Sr.
Branch Banking & Trust Co
200 South College St
Charlotte, NC 28202 |
