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FDIC Federal Register Citations Community Bank & Trust From: Mike Lee [mailto:mlee@cbtwaco.com] October 12, 2004 Mr. Robert E. Feldman Re: RIN Number 3064-AC50: FDIC Proposed Increase in the Threshold for the Small Bank CRA Streamlined Examination Dear Sir: I am Mike Lee, Vice President of Community Bank & Trust, located in Waco, Texas, a central Texas community of over 100,000 residents. My bank is $270,000,000 in assets and is already subject to large bank CRA exam. I am writing to strongly support the FDIC's proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of the bank's holding company. This would greatly relieve the regulatory burden imposed on many small banks such as my own under the current regulation, which are required to meet the standards imposed on the nation's largest $1 trillion banks. I understand that this is not an exemption from CRA and that my bank would still have to help meet the credit needs of its entire community and be evaluated by my regulator. I strongly oppose making the Community Development criterion a separate
test from the bank's overall CRA evaluation. For a community bank, Community
Development lending is not significantly different from the provision of
credit to the entire community. The current small bank test considers the
institution's overall lending in its community. The addition of a category
of Community Development lending (and services to aid lending and
investments as a substitute for lending) fits well within the concept of
serving the whole community. A separate test would create an additional
Community Development obligation and regulatory burden that would erode the
benefit of the streamlined exam. In conclusion, I believe that the FDIC has proposed a major improvement in the CRA regulations, one that much more closely aligns the regulations with the Community Reinvestment Act itself, and I urge the FDIC to adopt its proposal, with the recommendations above. Thank you for your consideration of my opinion. Sincerely,
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| Last Updated 10/28/2004 | regs@fdic.gov | |