FDIC Federal Register Citations

From: Michael Shriner [mailto:mshriner@millingtonsb.com]
Sent: Wednesday, October 20, 2004 2:23 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50

Michael Shriner
Executive Vice President
Millington Savings Bank
1902 Long Hill Road
Millington, NJ 07946

October 20, 2004

Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Dear Robert Feldman:

As a community banker, I am pleased to comment in support of the proposal issued by the FDIC that would amend the definition of a small institution to be a bank that is under $1 billion in assets. I believe that this change will provide much needed regulatory burden relief for me and other community bankers. It seems that every week there is a new or additional regulation with which we must comply. This is one example of regulatory burden relief that will really make a difference. I would much rather use the limited resources available to my bank to serve my community than to collect and maintain data and documents to prove to examiners that I am meeting the needs of my community.

Millington Savings Bank is a mutual savings bank located in Millington, New Jersey, with an asset size of $230 million and three branches located in Morris and Somerset Counties. We are scheduled to open two additional branches within the next 12 months. Millington Savings Bank currently employs 54 full and partime emolyees.

Compliance with the Community Reinvestment Act is something we take very seriously at our bank. We don’t just believe it is the right thing to do; we believe it is the right business thing to do. No community bank can survive and compete without meeting the needs of its customers and communities. We believe in our community and in our customers and want to work with them to provide products and services that best meet their credit needs. We do not need a complicated examination process to show that we are complying with the law.

It is absurd to think that a bank thousands of times larger than my own community bank should be examined using the same procedures. I strongly urge you to amend the definition of a small bank for CRA purposes to be an institution with less than $1 billion in assets, regardless of whether the bank is part of a holding company. This is a good proposal and is the right thing to do.

Thank you for considering my views.

Sincerely,
Michael Shriner
908-647-4000
Executive Vice President
Millington Savings Bank