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FDIC Federal Register Citations Plaza Bank September 9, 2004 Robert E. Feldman, Executive Secretary RE: 12 CFR Part 345 Dear Mr. Feldman: I am writing today to express support for the FDIC's proposed revision to the Community Reinvestment Act that would change the definition of a small bank to $1 billion regardless of holding company affiliation. When I began my banking career over 23 years ago, the definition of a small bank at that time was generally considered to be below $100 million. Also at that time, the biggest banks in the Chicago area were approximately $20 billion in asset size. Obviously today everything has changed. We now have three huge banking organizations each with assets above $1 trillion and very few banks below $100 million can even survive in today's economic environment. I think changing the definition is just recognizing what has occurred in the banking industry and is only a logical response from the FDIC. As president of Plaza Bank which as of this date has footings of approximately $350 million, I can tell you that serving our communities is a top priority. When we compete against a host of huge multi-national organizations including JP Morgan Chase, Citibank, Washington Mutual, etc., we have to respond to the needs of our community and we have to do it in a very personalized way which emphasizes service. Our deposits are all local, our loans are all local, our ownership is local and our management team is all local. The fundamental principal behind the creation of the Community Reinvestment Act was to insure that financial institutions did not simply take deposits from a geographic area without reinvesting in the same geographic area. I believe this requirement was always geared towards larger banks and smaller community based banks like Plaza Bank generally conduct the vast majority of their business in their nearby communities. As you are aware, in order to comply with the CRA provisions each bank must expend a certain amount of energy and staffing in order to meet the paperwork provisions. Obviously these efforts also cost money. Generally speaking, greater reporting requirements equates to a greater amount of time spent on paperwork and a greater amount of financial resources allocated to compliance. I would rather have our personnel engaged in the business of gathering deposits and funding loan transactions than producing volumes of reports in an effort to meet federal mandates. Reducing unwarranted burden would permit us to focus on community development activities and opportunities in our market place. In conclusion, the proposed changes to the rule simply recognize the changing nature of the banking industry over the past several decades and certainly would not diminish what small banks like Plaza Bank provide to their communities. I believe the Federal Deposit Insurance Corporation proposed changes were well thought out and well analyzed in the August 20, 2004 federal register notice. Thank you for your consideration. Robert C. Wareham
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| Last Updated 10/23/2004 | regs@fdic.gov | |