FDIC Federal Register Citations

First State Bank


From: Jess Laird [mailto:JLaird@FSBAthens.com]
Sent: Tuesday, April 06, 2004 7:44 PM
To: Comments
Subject: 12 CFR Part 345, RIN 3064-AC50

Regarding the joint proposal to amend the Community Reinvestment Act, I would like to comment that I am in favor of changing the definition of “small institution” to mean an institution with total assets of less than $500 million, without regard to holding company assets. I have been told that a bill has been introduced in Congress proposing the level be raised to $1 billion. Given a choice, I would support this proposal over the $500 million proposal.

In my twenty years of working in community banks and the financial industry, I strongly believe that community banks as a whole are dedicated to the ideals and goals of the Community Reinvestment Act. I do not believe the large bank CRA exam as it now stands; particularly the loan, service, and especially the investment test are either fair or an efficient way to measure compliance with CRA.

In my opinion, raising the level to either $500MM or $1B will not diminish community bank’s compliance with the goals of CRA. Raising the levels will save significant resources which can be better applied.

Thank you for your consideration.

Jess Laird, President
First State Bank
Athens, Texas 75751