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FDIC Federal Register Citations First Independent Bank of Nevada October 19, 2004 Mr. Robert E. Feldman Re: RIN Number 3064-AC50 Dear Ladies and Gentlemen: I’m writing to strongly support the FDIC’s proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of the bank’s holding company. In our opinion, this would greatly relieve the regulatory burden imposed on small banks. Current regulations require small banks to meet the standards imposed on the nation’s largest $1 trillion banks. Community banks, like ours, would still be required to help meet the credit needs of our entire community and would continue to be evaluated by our regulator. Our bank also strongly opposes making the CD criterion a separate test from the bank’s overall CRA evaluation. This creates the impression that CD lending is different from the provision of credit to the entire community. The current small bank test considers the institution’s overall lending in its community. The addition of a category of CD lending (and services to aid lending and investments as a substitute for lending) fits well within the concept if serving the whole community. A separate test would create an additional CD obligation and regulatory burden, eroding the intent of the streamlined exam. In addition, we strongly support the FDIC’s proposal to change the definition of “community development” from only focusing on low- and moderate-income area residents to including rural residents. This change will go a long way toward eliminating the current distortions in the regulations that result in a small rural bank being told to invest in regional affordable housing bonds for an urban area not in the bank’s community. Thank you for your consideration. Sincerely,
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| Last Updated 11/15/2004 | regs@fdic.gov | |