FDIC Federal Register Citations

Georgia Bank and Trust Company

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:

I am Executive Vice President responsible for Business Development and the CRA Performance of Georgia Bank & Trust Company located in Augusta, Georgia. Our Bank has assets of $680 million and was recently examined by the FDIC using the large bank CRA criteria. This exam, as well our prior examination, revealed the difficulties our Bank has in meeting the investment test since opportunities rarely occur and when they do, strong competition from other community banks as well as regional banks precludes our participation.

Since our Bank became subject to the CRA exam, we have been pleased with our ratings from a loan and service test and yet extremely disappointed and frustrated with our “Needs to Improve” rating on the investment test. It is Georgia Bank and Trust Company’s desire to be recognized for its total commitment to the community and I am writing to support FDIC’s proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of a bank’s holding company. We fully understand that this provision is not an exemption from CRA and that our Bank’s requirement to meet the credit needs of the entire community and examinations by our regulatory agencies remain consistent.

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. 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. A separate test would create an additional CD obligation and regulatory burden that would erode the benefit of the streamlined exam. Keeping the focus of small institutions on lending, which the small institution examination does, would be entirely consistent with the purpose of CRA which is to insure that the regulatory agencies evaluate how institutions help to meet the credit needs of the communities they serve.

I also suggest that the large bank test requirements are proving to be unworkable because multi-billion dollar banks are regularly outbidding smaller banks for qualified investments. I believe that the FDIC has proposed a major improvement in the CRA regulations, one that much more aligns the regulations with the Community Reinvestment Act itself and I urge the FDIC to adopt this proposal with the recommendations mentioned above.

Sincerely,

J. Pierce Blanchard
Executive Vice President