FDIC Federal Register Citations

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WEST SHORE BANK

From: Chuck Keller [mailto:chuckk@westshorebank.com]
Sent: Monday, March 01, 2004 4:51 PM
To: Comments
Cc: Arlen McCloskey

Subject: Comments on proposed amendments to Reg BB - Community Reinvestment Act

I have been a community banker for almost 29 years. Over those 29 years I have seen the compliance burden grow to a point now that it has become a burden on the consumer, whose rights were suppose to be protected by these new regulations. When I first began to make mortgage loans we could close the loan with less than eight documents. Now before the customer even sees the final closing documents they are inundated with at least that many “early disclosures” most of which is of no concern to them.

This year is the first year we were subject to the “large bank” CRA. Now we are expected to adhere to the same reporting requirements as a $10 billion bank. From a CRA standpoint we have always received a one rating or satisfactory rating. We offer programs that cover every consumer income range including two programs that offer 100% financing for the purchase of a new home. We offer numerous “small business” loans to individuals, corporations and partnerships.

We have enough regulatory burden now and could use some relief and by increasing the large bank threshold to $500 million would be a step in the right direction. We realize what CRA is meant to accomplish and I feel we do a great job meeting the credit needs of the community.