FDIC Federal Register Citations

WESTERN BANK


From: Cindy Bauer [mailto:CBauer@western-bank.com]
Sent: Wednesday, March 31, 2004 1:28 PM
To: Comments
Subject: Proposed CRA amendments comment

Western Bank's main location is in St Paul, Minnesota. We have 5 other offices in the Minneapolis/St Paul metro area. We hit the $250 million in assets in 2000 and were just reviewed for CRA compliance in March 2004 using the large bank rules.

As one that has just been through a large bank CRA exam, I believe the "regulatory burden" of large bank CRA rules is tremendous. The amount of time to gather and keep monitoring/documentation as to what we do is very time consuming. As a community bank that was formed in 1913, we meet the needs of our community as evidenced by our past small bank CRA compliance exams. For the most recent CRA exam, our lending and service records continue to back up our outstanding rating.

It is hard for a smaller 'large' bank to compete with the > $1 billion banks for CRA investments. While I understand the need to objectively review (thus your point structure) community developmment, it appears that one could "buy" their CRA investment test. This is not what the CRA regulation had intended.

I believe that large billion dollar banks and community banks are two different types of organizations. Therefore I fully support the increase in the size test for financial institutions being either a small or large bank. I wonder if increasing from $250 milliion to $500 million is a large enough jump. I would propose moving the benchmark higher to at least $750 million or $1 billion.

Cindy Bauer
Assistant Vice President
Western Bank
651-290-7882