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FDIC Federal Register Citations CSB Bank Mr. Robert E. Feldman I am 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. I understand that this
is not an exemption from CRA and that my bank would still have to help
meet the credit needs of its entire community and be evaluated by my
regulator. This would significantly reduce the regulatory burden of our
bank when we reach the magic $250 million mark. An additional reason
to support the FDIC's CD criterion is that it significantly reduces
the current
regulation's "cliff effect." Today, when
a small bank goes over $250 million, it must completely reorganize its
CRA program and begin a massive new reporting, monitoring and investment
program. If the FDIC adopts its proposal, a state nonmember bank would
move from the small bank examination to an expanded but still streamlined
small bank examination, with the flexibility to mix Community Development
loans, services and investments to meet the new CD criterion. This would
be far more appropriate to the size of the bank, and far better than
subjecting the community bank to the same large bank examination that
applies to $1 trillion banks. This more graduated transition to the large
bank examination is a significant improvement over the current regulation. I 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. I think that this change in the definition will go long way toward eliminating the current distortions in the regulation. We caution the FDIC to provide a definition of "rural" that will not be subject to misuse to favor just affluent residents of rural areas. Our area is populated by a majority of low to moderate income individuals, however none of this loans “count” towards a lending test under current CRA rules. In conclusion, I believe that 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. In a community such as ours, we would be dead in the water if we did not commit to Community Reinvestment in it’s truest sense by contributing to our community and lending to our local area.
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Last Updated 11/10/2004 | regs@fdic.gov |