FDIC Federal Register Citations

September 20, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Hand Delivered

Re: RIN Number 3064-AC50:

Dear Mr. Feldman:

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 imposed on small banks under the current regulation, which are required to meet the standards imposed on the nation's largest $1 trillion banks. Community banks would still be required to help meet the credit needs of their entire communities and would continue to be so evaluated by their regulator.

We 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 (CD) criterion. The new CD criterion should be applied only to banks greater than $500 million up to $1 billion. Community banks up to $500 million now hold about the same percent of overall industry assets as community banks up to $250 million did a decade ago when the revised CRA regulations were adopted, so this adjustment in the CRA threshold is appropriate. As FDIC examiners know, it has proven extremely difficult for small banks, especially those in rural areas, to find appropriate CRA qualified investments in their communities. Many small banks have had to make regional or statewide investments that are extremely unlikely to ever benefit the banks' own communities. This result certainly was not intended by Congress when it enacted CRA.

Sincerely yours,

Lloyd I. Hendricks
President & CEO
South Carolina Bankers Association
2009 Park Street
Columbia, SC 29202