FDIC Federal Register Citations

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

My letter is not going to be the form letter that is flooding your postal box and e-mail inbox. While I support the proposed changes to CRA, I feel that using asset size of a bank once again misses the mark in fulfilling the intent of the Community Reinvestment Act.

I have never been CRA Officer as a "small bank", so I am not sure what relief I would experience under a small bank test, but as a $900 million + community bank, I would think by our next exam, we will be $1 Billion and I will see no change at all if the change is made.

I recently attended the EGRPRA meeting in Chicago and spoke my mind there, stating that I believe that the distinction should be made by the nature of the bank (and perhaps the size of branch network), not by asset size. Whether it be broken down by urban, rural, agricultural, etc., there must be a better way.

Assuming we go over $1 Billion in assets, frankly, we are still a small community bank, serving a very small geographical area, with 7 locations, which just happen to be in a fairly affluent region. We don't have low-moderate income tracts in our AA - we have very few middle income tracts. We have a family-owned bank who are as philanthropic as they come, pouring hundreds of thousands of dollars annually into our community, many of those dollars benefiting the small percentage of low-moderate income families living within our boundaries. We also pour money into our schools, our religious and civic organizations, senior centers, athletic programs, etc.

I can proudly state that my employer is the largest business contributor to our community by far, and has consequently earned a place in the heart of the residents and businesses who live in this community.

At no fault of our own, there is just not a whole lot of opportunity for community development lending or investing in our AA (as defined by the CRA regulations), and what opportunity there is is far and few between and can usually be snapped up by the larger banks. We have employees and managers and Exec VPs and our Chairman volunteering throughout our community; we do an awful lot here and we are proud of that fact.

What bothers me the most is that to try and satisfy the regulations and to come out of an exam with a good rating, I am almost forced to spend my time looking for investment opportunities that may help in our exam, but frankly don't do a thing for our community. I can purchase a CD from Shore Bank in Chicago and get Investment Test credit. I understand the reasoning, but frankly, that doesn't take any innovative thinking and does not directly help my community. I can purchase mortgage-backed securities from ABN AMRO and get investment test credit. Again, not innovative and not directly helping my community.

The name of the regulation is COMMUNITY Reinvestment Act. Every bank operates in a distinctive community. Some banks obviously operate in a wide variety of communities all over the country. That is a difficult one to judge, I give you that. But for true community banks (like the one I am proud to work for), I would desperately like to see some congratulatory handshakes from my examiners (and if you must get quantitative, some good scores) for a consistent job well done within our community.

Thank you.

David M. Kreiman
SR. VP - CRA Officer
Glenview State Bank
800 Waukegan Rd
Glenview IL 60025
47-832-0344 (phone & fax) dkreiman@gsb.com