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PlantersFIRST From: Cynthia Ledford [mailto:cledford@plantersfirst.com]
Sent: Monday, August 16, 2004 11:33 AM
To: Comments
Subject: 3064-xxxx
To Whom It May Concern:
In reviewing the proposed changes to CRA, I feel that this would be a
positive change for small banks. Many banks through consolidation of
assets, have move up into the large bank criteria, but the criteria for
the large bank, as it is now, makes the Investment portion of the
requirement difficult for banks our size ($300M) to meet. Many banks our
size and like us, are located in rural communities, therefore limiting
the opportunities we have to meet the Investment portion of the Lending,
Investment and Service Test.
We received a CRA examination earlier this year and received a
Satisfactory. This was our first exam as a Large Bank. Previously we had
been receiving “Outstanding” but we were not able to meet the additional
Community Development “Investment” criteria as a Large Bank. Again, the
examiner agreed that this was not the fault of the bank due to the
limited opportunities. She noted that we were very active in all
community development services and often took the lead role in our
communities but our qualified investments were at best, adequate and
were documented on the Performance Test as “Low Satisfactory” for both
the Investment and Service tests. Therefore, she recommended
“Satisfactory” for our CRA Evaluation, which we are still pleased with
given this was our first evaluation as a “Large Bank”.
I believe most banks that are in our position would welcome some
relief from additional requirements that stem from consolidation of
branches and not from the way our banks operate or provide financial
services to all our designated communities. I do not feel that a change
such as the ones being proposed would have any adverse action in the way
banks are meeting the needs of low- and moderate-income individuals.
Sincerely,
Cynthia P. Ledford
Compliance Officer
PlantersFIRST, Cordele, Ga.
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