FDIC Federal Register Citations

9/15/04

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:

As a community banker, I join my fellow community bankers throughout the nation in strong support of the FDIC's proposal to increase the assets size limit of banks eligible for the streamlined small-bank CRA examination. I also strongly support the elimination of the separate holding company qualification. Streamlining the CRA exam is not an exemption from CRA. Community banks would continue to be examined to ensure they lend to all segments of their communities. One of the problems with the current large bank CRA exam is that the definition of "qualified investments" is too limited, and qualified investments can be difficult to find. As a result, many community banks (especially those in rural areas) have to invest in regional or statewide mortgage bonds or housing bonds to meet CRA requirements. These investments may benefit other areas of the state or region, but they actually take resources away from the bank's local community. If banks could truly reinvest those dollars locally, their community's economies and residents would be better off. For this reason, I find that the FDIC's .proposed community development requirement for banks between $250 million and $1 billion is more flexible and more appropriate than the large bank investment test.

First International Bank & Trust is committed to the communities that we serve and responsive to the communities' needs. The proposal continues to focus on community development, but considers investments, lending and services. It would allow community banks to pursue community development activities that meet the local community's needs. The proposal will help rural banks meet the special needs of their community but expanding the definition of "Community Development" so that it includes activities that benefit rural residents in addition to low- and moderate-income individuals.

First International Bank & Trust is frequently called upon to support needed economic or infrastructure development such as school construction, revitalizing Main Street, or loans that help create needed and better paying jobs. For many small towns and rural communities, the loss of the local bank can be catastrophic to the area.

The FDIC's proposed changes to CRA will greatly alleviate the unnecessary paperwork and examination burden without weakening our commitment to reinvest in our communities. Without changes such as this, more and more community banks will find they cannot sustain independent existence because of the crushing regulatory burden. By easing regulatory burden, community banks like mine will continue to provide committed service to areas that few other financial service providers are willing to invest their CRA dollars.

Thank you for considering my views.

Sincerely,
Sephen L. Stenehjem
President