FDIC Federal Register Citations

Firstbank

From: Bob Wheeler [mailto:bobw@firstbank-corp.com]
Sent: Saturday, September 18, 2004 10:28 AM
To: Comments
Cc: psmith@aba.com
Subject: Small bank CRA Exemption

Dear Mr. Feldman,

My name is Bob Wheeler, and I am a Senior Vice President at Firstbank in Mt. Pleasant, Michigan. We are a community bank and are currently tested under the small bank CRA examination. I am in support of passage of RIN No. 3064-AC50, the extension of the small bank exception up to $ 1 Billion.

Most community banks are composed of people within the community who take pride in being a part of that community. Our primary focus is service to that community, both lending, deposit and our own personal time. There is a huge difference between these community banks and the mega bank, yet the distinction rarely benefits us. We have the same regulatory burden that the large banks have, yet without the resources. Every time the CRA result are posted, I notice the vast majority of the community banks receive a Satisfactory or Outstanding rating. This the perfect bill to see that our community banks, the lifeblood of our rural areas, are given the credit they deserve in minimizing the regulatory burden.

I also oppose the concept of making the Community Development test separate from the banks overall CRA evaluation. To do this would continue to add to the regulatory burden of the small community bank.

Thanks for listening to me and I hope you will consider my comments.
Bob Wheeler