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FDIC Federal Register Citations Tri-County Bank From: Ferguson, John [mailto:John.Ferguson@abcbancorp.com] I am John Ferguson President of Tri-County Bank, located in Trenton, Florida with a branch in Newberry, Florida which is in Alachua County near Gainesville, Florida. Our CRA Assessment Area consists of all of Gilchrist County and portions of Levy County and Alachua County. The population of Gilchrist County is 14,437and the population of Levy County is 34,450. Alachua County has a population of 217,955 and contains the city of Gainesville, Florida. Gainesville is an MSA and in 2004 Gilchrist County became a part of the MSA. However, Gilchrist County is still mainly a rural area. Tri-County Bank has assets of $65,905 but is classified as a large bank under CRA because it is owned by ABC Bancorp located in Moultrie, Georgia, a holding company of over $1 billion in assets. I am writing to inform you that I strongly feel that the $1 billion threshold is appropriate when dealing with individual banks, and without regard to the holding company assets of $1 billion or less. Each bank should have its own threshold, regardless of holding company asset size. The regulatory burden imposed on small banks under the current regulation is tremendous and could be reduced substantially by the passing of this proposal. I believe in the Community Reinvestment Act and support its underlying principles of serving the deposit and credit needs present in our communities especially those of low- and moderate-income people and census tracts. However, under the large bank requirements of loan coding, paperwork and reporting we are hindered from carrying out the original purpose of CRA. Our time could be better spent in customer service to the entire community if we were not under the large bank requirements. Furthermore, for small banks between 250 million and 1 billion I support the addition of a separate community development test in addition to existing streamlined performance criteria applicable to small banks to evaluate community development activities. I believe that the performance rating should be based upon effort as it relates to opportunities that exist in the community. More weight should be given to community activities and community involvement rather than just loans. This would prove to be more advantageous to the communities our banks are located in. The rating should be tied to the strengths and opportunities that the bank has at its disposal. There should be some balance with results versus opportunities.Lastly, I support the FDIC's proposal to change the definition of "community development" from only focusing on low- and moderate-income area residents to including residents of rural areas. Also, that definition should be expanded to incorporate all such activities with no regard to social status of recipients. In a small rural type setting exclusion of anyone or any area is typically not an issue as these community development services and activities are enjoyed by all. The definition of rural should be based upon density of population in a defined area. I believe the FDIC has proposed a great improvement in the CRA regulations. This improvement will align with the original meaning of the Community Reinvestment Act and I urge the FDIC to adopt its proposal. I will be happy to discuss this matter further with you. Sincerely, John Ferguson John Ferguson
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| Last Updated 11/10/2004 | regs@fdic.gov | |