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BANK OF UTAH
September 24, 2004
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
Dear Mr. Feldman:
I am writing in support of the FDIC proposal to increase the
threshold for small bank CRA streamlined examinations to $1billion. We
are a locally owned community bank with total assets of $562 million. As
the Bank’s CRA officer, I was personally involved in our transition from
a small bank to a large bank classification for purposes of the
Community Reinvestment Act. We stepped into a brand new arena with a
tremendous increase in regulatory burden. The primary purpose of CRA, in
my opinion, is to make certain that our bank is meeting the credit needs
of the communities that we serve. We are a community bank. The “lending
test” that regulators use to evaluate a small bank’s lending activities
seems to serve this purpose well. As it is now, our community bank is
evaluated under the large bank scenario using the same standards and
measurements to evaluate banks approaching $1 trillion dollars in size.
We struggle with community development lending and CD investments.
The competition in our state for community development loans and
investments is significant. Our state charters industrial loan
corporations who have a voracious appetite for community development
investments. They too have CRA obligations to meet. Utah also has
several large multi-billion dollar banks that also compete for CD loans
and investments. While we support the addition of a community
development criterion for “small bank” examinations, we are strongly
opposed to making the community development criterion a separate test
from the bank’s overall CRA evaluation. A separate test would create an
additional community development obligation and regulatory burden that
undermines the intent of a streamlined CRA examination.
In conclusion, I believe that the FDIC has proposed a major
improvement in the CRA regulations, one that much more closely aligns
the regulations with the Community Reinvestment Act itself, and I urge
the FDIC to adopt its proposal, with the recommendations above.
Sincerely,
A. Rand Matthews
Sr. Vice President
Bank of Utah
2605 Wash Blvd.
Ogden, UT |
