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FDIC Federal Register Citations Rio Grand Savings and Loan Association September 13, 2004 Robert E. Feldman Re: COMMUNITY REINVESTMENT ACT – RIN 3064-AC50 Dear Mr. Feldman: As a community banker, I am pleased to comment in support of the proposal issued by the FDIC that would amend the definition of a small institution to be a bank that is under $1 billion in assets. I believe that the proposed change will provide much-needed regulatory burden relief for all community banks operating in this country. The proposed rule is one example of regulatory burden relief that will make a difference in the day-to-day operations of financial institutions. Instead of spending countless hours accumulating reams of paperwork, most of which only serves to build a bulky file, banking institutions under $1 billion in asset-size will be permitted to focus greater attention on housing initiatives geared toward community development. Roma Bank is a $695 mutual thrift institution based in Mercer County, New Jersey. We pride ourselves in having attained five "Outstanding" CRA ratings from the Office of Thrift Supervision, with the last three ratings being consecutive scores of "Outstanding". To achieve our superior ratings, we have had to develop strategies, and dedicate filing cabinets, to show our compliance with all three of the tests (i.e., lending, investment, and service) that are conducted by the CRA compliance examiner. Upon adoption, the proposed new rule will lessen the paperwork-accumulation process, permitting us to focus more attention on pro-active CRA lending strategies. We welcome the opportunity to comment on the proposed rule, and we look forward to the promulgation of the final rule. We applaud the FDIC on taking a much-needed, and long overdue, step in enacting regulatory burden relief. Sincerely,
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| Last Updated 10/23/2004 | regs@fdic.gov | |