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WILBER NATIONAL BANK
September 20, 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
Dear Mr. Feldman:
Our bank is a 130-year-old community bank with approximately $740
million in assets serving six mostly rural counties in upstate New York.
We have, throughout our history, regarded ourselves as a strong
corporate citizen and our position in that regard was long before the
passage of CRA legislation some 30 years ago. I might add that in those
thirty-plus years, no one except college students doing papers has asked
to see our CRA public file.
Although we have a national charter, we strongly support the FDIC's
proposal to raise the threshold for the streamlined small bank CRA
examination to $1 billion without regard to the size of the bank's
holding company: This would greatly relieve the regulatory burden
currently imposed on small banks, which are now required to meet the
same standards imposed on the nation's largest $1 trillion banks. In our
specific case, we estimate an annual expenditure of 2400 hours and a
cost of $50,000 for us to compile data in support of our community
reinvestment activities.
We also support the addition of a community development criterion to
the small bank examination for larger community banks, but we believe
that the FDIC should adopt its original $500 million threshold without a
community development criterion. The new community development criterion
should be applied only to banks greater than $500 million up to $1
billion. As field examiners know, it has proven extremely difficult for
small banks to find appropriate CRA qualified investments in their
communities.
We thank you for recognizing that "one size does not fit all" when it
comes to CRA, and we urge you to adopt your proposal.
Douglas C. Gulotty
Executive Vice President
Wilber National Bank
Oneonta, NY
cc: The Honorable John D. Hawke, Jr.
Mr. Bradley E. Rock |
