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Itasca Bank & Trust Co.
Itasca Bank & Trust Co.
308 W. Irving Park Road
Itasca, Illinois 60143
April 5, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: Community Reinvestment Act Regulations
Dear Sir:
As a community banker, I strongly endorse the federal bank
regulators' proposal to increase the asset size of banks eligible for
the small bank streamlined Community Reinvestment Act (CRA) examination
from $250 million to $500 million and elimination of the holding company
size limit (currently $1 billion). This proposal will greatly reduce
regulatory burden. I am the Compliance Officer of Itasca Bank & Trust
Co., a bank with $335 million in assets, located in Itasca, Illinois.
Adjusting the asset size limit more accurately reflects significant
changes and consolidation within the banking industry in the last 10
years. To be fair, banks should be evaluated against their peers, not
banks hundreds of time their size. The proposed change recognizes that
it's not right to assess the CRA performance of a $300 million bank with
the same exam procedures used for a $300 billion bank. It is not fair to
rate a community bank using the same CRA examination. And, while the
proposed increase is a good first step, the size of banks eligible for
the small-bank streamlined CRA examination should be increased to $2
billion, or at a minimum, $1 billion.
Increasing the size of banks eligible for the small-bank streamlined
CRA examination does not relieve banks from CRA responsibilities. Since
the survival of many community banks is closely intertwined with the
success and viability of their communities, the increase will merely
eliminate some of the most burdensome requirements.
In summary, I believe that increasing the asset-size of banks
eligible for the small bank streamlined CRA examination process is an
important first step to reducing regulatory burden. I also support
eliminating the separate holding company qualification for the
streamlined examination, since it places small community banks that are
part of a larger holding company at a disadvantage to their peers. While
community banks still must comply with the general requirements of CRA,
this change will eliminate some of the most problematic and burdensome
elements of the current CRA regulation from community banks that are
drowning in regulatory red-tape. I also urge the agencies to seriously
consider raising the size of banks eligible for the streamlined
examination to $1 billion in assets to better reflect the current
demographics of the banking industry.
Sincerely,
Dolores Little
Vice President/ Compliance Officer
Itasca Bank & Trust Co.
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