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BANK OF TERRELL
March 22, 2004
Robert E. Feldman, Executive Secretary
ATTN. Comments
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429
Re: 12 CFR Part 345
Proposed Revisions to the Community Reinvestment Act Regulations
Dear Mr. Feldman:
This letter is to express our bank's support to the federal
regulatory agencies' proposed amendment to CRA to increase the asset
size of what is considered to be "small institutions" and to eliminate
any consideration of whether the small institution is owned by a holding
company. These proposed changes are overdue and will greatly lessen
current and future regulatory burdens.
The current "small institutions" assessment test is satisfactory for
smaller banks (we are a $100 million bank, part of a 3 bank $210 billion
holding company). All three banks have always received satisfactory or
better marks on CRA ratings and continue to strive to provide financial
services to all of our communities. When the small institution test was
enacted in 1995, it greatly relieved unnecessary regulatory burden and
paperwork. All three banks are located in small, rural communities with
town populations of less than 5,000 people. It simply would not be
prudent banking nor business practice to not service our community to
the greatest extent possible. Due mainly to inflation, it is not
unreasonable to think that some time in the future our bank could reach
$250 million in assets. Certainly, there are many banks in our similar
situation who do an excellent job of servicing their communities
financial needs and should not be penalized because they have grown due
to increased "costs of living." Please do consider raising the current
asset size to $500 million and include future clauses to provide for
additional raises in asset size should the cost of living warrant
increases in the future (because it most likely will).
As you can see from the numbers above, our holding company, the
Georgia Community Bancorp, is approaching the holding company asset
limit. Although all 3 of the banks in our holding company have similar
market areas and service each one to the best of their extent, each bank
does operate independently of one another. Trying to coordinate a
holding company wide large bank assessment test would be very difficult,
time consuming and expensive. In the end, it would not provide any
additional useful information to regulators and only serve to increase
regulatory burden. $250 billion is not considered a large holding
company by today's standards. Increasing this limit to at least $500
billion will continue to streamline bank examinations.
In conclusion, when CRA was revised in 1995, it greatly reduced
regulatory "red-tape". However, the asset sizes used then did not take
into consideration normal growth of even truly small community banks and
holding companies like ours. We strive everyday to meet the financial
needs of our community; please take this into consideration when making
your decision.
Sincerely
Lucie Beeley
Bank of Terrell, Dawson, Georgia (229) 995-4461
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