FDIC Federal Register Citations

September 22, 2004

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

Re: RIN Number 3064-AC50: FDIC Proposed Increase in the Threshold for the Small Bank CRA Streamlined Examination

Dear Mr. Feldman:

I am the President of a $234 million bank located in Grand Rapids, Michigan. As a community banker, I strongly support the FDIC's proposal to increase the asset size limit of banks eligible for the streamlined small-bank CRA examination to $1 billion. The FDIC's proposal will alleviate the CRA examination burden faced by community banks without weakening our commitment to reinvest in our communities. Making it less burdensome to undergo a CRA exam will not change the way my bank does business. Reinvesting in our communities is something we do everyday, as we will not survive if the local community does not thrive. That means it is in my bank's best interest to be responsive to community needs and promote and support community and economic development. It is also important to remember that the streamlined CRA exam is not an exemption from CRA. Banks subject to the simplified CRA exam are still fully obligated to comply with CRA. However, it does not make sense to evaluate a $1 billion bank using the same exam procedures as for a $100 billion bank.

I also support the FDIC's proposed community development requirement for banks between $250 million and $1 billion because it is more flexible and more appropriate  than the large bank investment test. The current definition of qualified investments results in many community banks having to investing regional or statewide mortgage bonds, housing bonds and similar types of investments to meet their CRA investment requirements. As a result, resources are actually taken away from the bank's local community. Local communities would be better off if community banks could focus on community development investments, lending, and services that benefit their own local economies and residents.

In addition, the FDIC's proposal to expand the definition of community development to include activities that benefit rural areas should be adopted. Activities that support economic development, infrastructure development, the creation of better paying jobs; etc. in rural areas should not be ineligible for CRA credit simply because they do not benefit only low- or moderate-income individual's.

In summary, I strongly Support the FDIC's proposed changes to CRA, and I commend the FDIC for its attempt at easing the regulatory burden' in order to make it easier for community banks like mine to continue to provide the investments and services to local communities that few other financial service providers are willing to provide

Sincerely,

Charles A. Williams, President & CEO
Northpointe Bank
Grand Rapids, MI