FDIC Federal Register Citations

Georgia Bank & Trust Company
3530 Wheeler Road
Augusta, Georgia 30909

October 19, 2004

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

Re: RIN Number 3064-AC50
Dear Mr. Feldman:

As President & CEO of Georgia Bank & Trust, I am writing to support increasing the threshold for the streamlined small bank CRA examination to $1 billion without regard to size of the bank’s holding company. Since our Bank is required to meet the same standards imposed on the larger trillion-dollar banks, this increase would greatly relieve the regulatory burden imposed on small banks. We do understand that this is not an exemption from CRA and that our Bank will still be required to help meet the credit needs of our entire community and be evaluated by our regulators.

I also support the addition of a community development criterion to the small bank examination for larger community banks. It appears to be a significant improvement over the investment test since many small banks have had to make regional or statewide investments that are extremely unlikely to benefit the banks’ own communities. That was certainly not the intent of Congress when it enacted CRA.

I strongly oppose making the CD criterion a separate test from the bank’s overall CRA evaluation. For a community bank, CD lending is not significantly 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 fits well within the concept of serving the whole community. A separate test would create an additional CD obligation and regulatory burden that would erode the benefit of the streamlined exam.

I believe the FDIC has proposed a major improvement in the CRA regulations, one that much more closely aligns the regulations with the Community Reinvestment Act itself, and I urge the FDIC to adopt its proposal, with the recommendations above.

Sincerely,

R. Daniel Blanton