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Bank of the Pacific
Wednesday, February 18, 2004
Federal Deposit Insurance Corporation
Robert Mooney, Assistant Director
550 17th Street, NW
Washington, DC 20429
Dear Mr. Mooney:
In response to your request that all banks give comment on the
proposed rulemaking regarding the Community Reinvestment Act, we have
several points to offer for your consideration.
The Bank of the Pacific is a community-based bank in rural coastal
communities located in Southwestern Washington. The banks mission
statement is to be the best to our employees, customers, investors and
communities. In the past two years we have been working on the
transition from small bank to large bank requirements. Our deposit size
continues to increase and we will approach the $500 Million proposed
threshold within the next year. In our current business climate and ever
growing economy we suggest that the threshold be raised to one billion
before being classified as a Large Bank.
The time commitment to meet all regulatory requirements under the
large bank designation is an unwarranted burden of time and expense. We
will continue to strive for personalized service in our small town
atmosphere and within the areas that we do business in spite of the
asset size.
Since we have been transitioning to Large Bank requirements we find
that the competition for Community Investments and Community Development
Loans are much more difficult to obtain. The bank does not have the
staff or the resources to compete in that market.
With regard to proposal two in your letter of February 6, 2004, to
better address evidence of illegal credit practices and abusive lending
practices, this already falls under the Fair Lending Act and other bank
compliance regulations and should not be considered here.
The regulation requirements should also extend to the participation
of other non-financial institutions such as Credit Unions, Mortgage
Companies and issuers of credit cards not affiliated with banks
presently reporting CRA activity.
Thank you for your time and consideration.
Laura C. Smith
CRA Officer
Bank of the Pacific
Aberdeen, WA
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