FDIC Federal Register Citations

From: Larry Dillon [mailto:LDillon@cffc.com]
Sent: Tuesday, October 12, 2004 4:59 PM
To: Comments
Subject: RIN: 3064-AC50

Citizens and Farmers Bank
P.O. Box 391
West Point, VA 23181
PH: (804) 843-2360

October 12, 2004

Via e-mail - comments@fdic.gov

Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, D.C. 20429

RE: RIN 3064-AC50
Community Reinvestment Act (CRA)

Dear Mr. Feldman:

On behalf of C&F Bank, a state of Virginia non-member bank, I applaud the FDIC's proposal to raise the definition of "small bank," for purposes of determining those banks eligible for the streamlined examination standards, from $250 million in assets to $1 billion in assets regardless of holding company affiliation. The arguments in support of such a change are compelling, and I urge the FDIC to finalize its proposal at the earliest possible time.

The regulatory burden on all banks, but especially small ones, has become enormous. With the additional strain put on us by the new requirements of the USA Patriot Act and the Sarbannes-Oxley Act, regulatory strain has reached a new high. Compliance with all the regulations now hits our bank particularly hard and any easy of that burden would be greatly appreciated.

CRA compliance costs are disproportionately higher on community banks that currently do not qualify for the streamlined test. This is certainly the case with our bank as we do not have the resources that the larger banks have to address CRA compliance. Raising this threshold to $1 billion will relieve our bank significantly without having any impact on how we serve the communities we serve, including low and moderate income communities.

Our bank lends to all segments of the communities we serve. "CRA" loans have always been and will always be an important part of our business. Raising the threshold to $1 billion will not reduce our "CRA" loans, but will reduce unnecessary and costly red tape.

In short, we commend the FDIC for pursuing the right course on this issue and we appreciate the opportunity to comment.

Sincerely,
Larry G. Dillon
President & CEO