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FIRST BANK & TRUST CO.
September 15, 2004
Federal Deposit Insurance Corporation
Robert E. Feldman, Executive Secretary
Attn: Comments/Legal ESS
550 17th Street, NW
Washington, DC 20429
Re: 12 CFR Part 345
As a community banker, I join my fellow community bankers throughout
the nation in strong support of the FDIC's proposal to increase the
asset size limit of banks eligible for the streamlined small-bank CRA
examination.
The proposal will greatly alleviate unnecessary paperwork and
examination burden without weakening our commitment to reinvest in our
communities. Reinvesting in our communities is something we do everyday
as a matter of good business. My community bank must be responsive to
community needs, promote and support community and economic development
in order to survive as a local bank.
Making it less burdensome to undergo a CRA exam by expanding
eligibility for the streamlined exam will not change the way my bank
does business. In fact, it will free up human and financial resources
that can be redirected to the community and used to make loans and
provide other services.
It is important to remember that the streamlined CRA exam is not an
exemption from CRA. Banks subject to the simplified CRA exam are still
fully obligated to comply with CRA. Just as now, community banks would
continue to be examined to ensure they lend to all segments of their
communities, including low- and moderate-income individuals and
neighborhoods. It just doesn't make sense and is inequitable to evaluate
a $500 million or $1 billion bank using the same exam procedures as for
$100 billion or $500 billion bank.
One of the problems with the current large bank CRA exam is that the
definition of "qualified investments" is too limited, and qualified
investments can be difficult to find. As a result, many community banks
(especially those in rural areas) have to invest in regional or
statewide mortgage bonds or housing bonds and the like to meet CRA
requirements. These investments may benefit other areas of the state or
region, but they actually take resources away from the bank's local
community. Community banks and communities would be better off if the
banks could truly reinvest those dollars locally to support their own
local economies and residents.
For this reason, I find that the FDIC's proposed community
development requirement for banks between $250 million and $1 billion is
more flexible and more appropriate than the large bank investment test.
The advantage to this proposal is that it continues to focus on
community development, but considers investments, lending and services.
It would let community banks pursue community development activities
that both meet the local community's needs and make sense in light of
the bank's strategic strengths.
Similarly, the proposal will help rural banks meet the special needs
of their communities by expanding the definition of "community
development" so that it includes activities that benefit rural residents
in addition to low- and moderate-income individuals. Rural banks are
frequently called upon to support needed economic or infrastructure
development such as school construction, revitalizing Main Street, or
loans that help create needed or better-paying jobs. These activities
should not be ineligible for CRA credit because they do not benefit only
low- or moderate-income individuals.
The FDIC's proposed changes to CRA are needed to help alleviate
regulatory burden. By easing regulatory burden, it will make it easier
for community banks like mine to continue to provide committed service
to local communities.
Thank you for allowing me the opportunity to comment.
Joann Best
Compliance/CRA Officer
First Bank & Trust Co.
Duncan, Oklahoma
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