FDIC Federal Register Citations

April 13, 2004

Robert E. Feldman, Executive Secetary
Attn:  Comments
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC  20429
RE: 12 CFR Part 345

Re:  Proposed Revisions to the Community Reinvestment Act Regulations

I am writing to support the federal bank regulatory agencies' proposal to enlarge the number of banks and savings associations that will be examined under the small institutions Community Reinvestment Act (CRA) examination. The agencies propose to increase the asset threshold from $250 million to $500 million and to eliminate any consideration of whether the small institution is owned by a holding company. This is clearly a step in the right direction for CRA and I support these acts.

In looking at our bank, converting to the large institution examination requires, among other things, that we devote additional staff time to documenting services and investments, which we currently do not do, and begin to geocode all of out loans that might have CRA value. This imposes a dramatically higher regulatory burden that drains both money and personnel away from helping to meet the credit needs of our community.

In conclusion, I strongly support increasing the asset-size of banks eligible for the small bank streamlined CRA examination process as a vitally important step in revising and improving the CRA regulations and in reducing regulatory burden. I also support eliminating the separate holding company qualification for the small institution examination, since it places small community banks that are part of a larger holding company at a disadvantage of their peers.

Sincerely yours,

Mark A. Butterfield,
Vice President, CRA Officer
Roundbank
200 2nd St. NE
Waseca, MN