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via e-mail
MAYFLOWER COOPERATIVE BANK March 2, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D.C. 20429
Dear Mr. Feldman:
I am writing to express my support for the proposed changes to CRA
regulations which would amend the definition of a “small institution” to
mean an institution with total assets of less than $500 million. I
presently serve as the Senior Lending Officer of a publicly traded,
state chartered thrift institution that is approaching the $250 million
asset mark. One wears many hats in an institution of this size, and
among the hats I wear is that of the bank’s CRA officer. Our CFO serves
as the bank’s compliance officer. We are not of a size that we believe
can support an individual devoted to compliance, and we outsource our
compliance audit function.
As a small, community bank, we face many challenges in our effort to
remain competitive with the larger institutions in our market. One of
the more daunting of these challenges is the regulatory compliance
burden. While economies of scale allow larger institutions to have
specialized personnel and departments devoted to the compliance
function, it is simply not practical for a bank our size. Yet in nearly
all compliance areas, we are expected to be fully knowledgeable, with
comprehensive procedures and systems in place to satisfy the myriad
requirements contained in thousands and thousands of pages of
regulations. CRA is one of the few areas where our size is taken into
account and, in my opinion, sensibly so.
It is my strong belief that our institution fulfills its CRA
obligations by simply doing business the way we always have. We make
home mortgages and small business loans and mortgages, largely within
our assessment area. We consistently receive high marks for lending to
borrowers of different incomes and in low to moderate income census
tracts. We do these things not because we are required to under CRA;
rather, it is simply the business we are in.
I do not see any benefit to the community that will accrue from the
more intensive record keeping and reporting requirements that will apply
once we cross the $250 million threshold. If anything, it will just make
it more difficult to continue doing the good job we are already doing.
It is for these reasons that I support the proposed changes.
Thank you.
Mayflower Cooperative Bank
John J. Biggio
Vice President
Senior Loan Officer
Telephone: 508-947-4343
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