Community Bank of Oak
Park River Forest
From: MartyN@cboprf.com [mailto:MartyN@cboprf.com]
Sent: Wednesday, April 21, 2004 6:02 PM
To: Comments
Subject: CRA Comments, Federal Register, Vol 69, No.25
I am President of 7-year-old Community
Bank of Oak Park River Forest, a $170 million commercial bank, FDIC
insured, which just finished a CRA exam earlier this year. As we
prepared for the exam I pooled the resources of three internal persons,
including myself, which totalled over 1000 hours and the effort of two
consultants. During that time we installed new data reporting systems,
reviewed a significant number of credit files and HMDA data, puchased/acquired
data comparing our institution to others in our market, installed a
formal reporting system for our Board of Directors and performed a self
assessment. We were rated a (strong) "Satisfactory."
The proposal to change the definition of
a "small institution" from $250 million to $500 million makes eminent
sense. The ongoing effort to be a "Satisfactory" (not to mention an
"Outstanding") CRA institution of our size requires resources already
badly stretched in the simple day to day task of running a bank. More
importantly, the difference in the examination methodology between a
small and a large institution would seem to indicate that a $260 million
institution would more closely resemble one of our large multi-billion
dollar bank brotheren than a small institution. Nothing could be farther
from fact. Enlarging the definition to $500 million would give
significant relief to smaller, resource-scarce institutions who benefit
most from their relationships with their immediate communities.
I realize that there has to be a large
institution designation at some size. It seems inappropriate that the
size is as small as $250 million. A more appropriate size might be $1
billion. My Board, staff and I support expanding the small institution
size to $500 million.
Martin J. Noll, President
Community Bank of Oak Park River Forest
1001 Lake St.
Oak Park, IL 60302
708-660-7010 |
