FDIC Federal Register Citations

From: Don Shamey [mailto:dshamey@thebank.com]
Sent: Wednesday, October 06, 2004 2:57 PM
To: Comments
Subject: RIN Number 3064-AC50

Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation

Mr. Feldman

I respectfully comment on the FDIC's proposal to redefine a small institution from a threshold of $250 million to $1 billion for CRA purposes. Being the CEO of a $450 million community bank, I fully support this proposal.

First, it is our mission to support all aspects of our community. We always have and always will. It's simply the way we do business.

Second, considering today's financial landscape it is inappropriate to consider an institution over $250 million as "large" in whatever context it be measured.

Third, it is very difficult for banks under $1 billion to comply with the investment test as it is currently measured. Why have a standard that is virtually impossible for smaller institutions to meet?

Fourth, community banks are drowning in regulatory compliance. Every bit of regulatory relief is welcomed and this proposal would be with open arms.

Finally, I appreciate the concern of the community activist groups with this change. However, upon a more thorough analysis, I'm sure they would find that banks under $1 billion are not typically the institutions that need CRA regulation. I refer back to my first point.

I'm sure that you've heard all of this before. The reason is that these are valid points in support of the FDIC's proposal. I commend your agency for its forthright stance on this issue.

Respectfully

Donald S. Shamey
CEO
Citizens National Bank of Evans City, PA