NEW HAMPSHIRE BANKERS ASSOCIATION
September 17, 2004
Mr.
Robert Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50
To Whom It May Concern:
The New Hampshire
Bankers Association (NHBA) is a not-for-profit trade association
representing
the 39 state- and nationally-chartered
banks in New Hampshire. Our member banks range in size from extremely
large, multi-state holding companies to small yet well-seasoned mutual
savings banks and de novo institutions. Despite the broad spectrum
of banks we represent, our Association is strongly united in its
support of the FDIC’s proposed increase in the threshold for
the Small Bank CRA Streamlined Examination.
It is common
knowledge nationwide that the de facto definition of a “small bank” is now $1 billion in assets or less. It
is also common knowledge that community banks across the country
are being crushed by the huge regulatory burden that has been placed
on the banking industry in general. Raising the threshold for the
streamlined small bank CRA examination to $1 billion without regard
to the size of the bank’s holding company would greatly reduce
this regulatory burden.
We also support
the addition of a Community Development criterion to the small
bank CRA test,
but only if it is applied to banks between
$500 million to $1 billion. Adding the new CD criterion to banks
below $500 million in assets would increase the regulatory burden
of extremely small institutions and be counterproductive. We also
believe that a new CD criterion should be part of the test to evaluate
an institution’s overall performance in meeting the needs of
its community and not a stand-alone test.
Finally, the
NHBA strongly supports the FDIC’s proposal to
change the definition of “community development” to include
rural residents as well as people who live in low- and moderate-income
areas. Two-thirds of New Hampshire lies in a rural region. Modifying
this definition would truly allow many small institutions to accurately
reflect their efforts to lend into the market areas where they collect
deposits. After all, that’s what CRA is all about.
Sincerely,
Gerald H. Little
President
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