FDIC Federal Register Citations

Cameron State Bank

October 18, 2004

Robert E Feldman, Executive Secretary
Attention: Comments / Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429

Ref: Proposed Amendments to CRA

Dear Mr. Feldmen:

In a proposed amendment to the Community Reinvestment Act in FIL–108–2004 your agency asked banks for their comments. This amendment would change the definition of a small institution to mean an institution with total assets of up to $1 billion.

I work for a community bank that has become a “large bank” under the CRA. Our institution has had to deal with the increased regulatory data and reporting community development loans. The data that is required on its small business is very burdensome.

The investment test for a community bank to attain a satisfactory rating is very difficult. We compete for suitable investments in our market with billion dollar regional and national banks that have an unfair advantage due to their size. They literally will spend whatever it takes to get those investments. The smaller institutions are then at a disadvantage during exam time.

Our institution is in favor of changing the definition of a small institution to one with total assets of up to $1 billion without regard to the holding company assets.

Sincerely,
Connie L Johnson
Asst. Branch Manager