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FDIC Federal Register Citations First Community Bank September
9, 2004 Re: RIN Number 3064-AC50 Dear Mr. Feldman: Although CRA regulations are essentially sound and serve a good purpose, I would like to express my support for the proposed rule to change the definition of "small bank" to raise the asset size threshold regardless of holding company affiliation The current definition of small bank excludes First Community Bank (FCB) with offices in Keokuk, IA and Carthage, IL as we are a member of Heartland Financial USA, Inc., a large holding company. Therefore, FCB was examined as a large bank during our most recent CRA exam. What a tough exam for our small bank, which is located in a very rural area. The large bank performance standards were very difficult for FCB to be measured against, and the process was frustrating for the bank employees as well as the examiners. FCB has always been conscientious of serving all sectors in our lending and community service actions. However, human, program and monetary resources are more limited in our small communities, so opportunities that meet the criteria are more difficult to identify. Our local community efforts are potentially damaged by our need to meet large bank criteria, data collection and reporting technical requirements rather than focusing on community-based lending activities and community improvement involvement. Rural communities raise noteworthy issues in the community development context and should receive consideration as such. The definition of community development should ensure that it encompasses activity that benefits rural areas. The proposed community development criterion would permit banks to better and more meaningfully balance their community development activities based on the opportunities in the market and their own strategic strengths. Thank you for considering my opinions.
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| Last Updated 10/25/2004 | regs@fdic.gov | |