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Federal Register Publications

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FDIC Federal Register Citations

Western Commerce Bank


September 20, 2004

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

Re: Community Reinvestment, RIN number 3064-AC50; Proposal to Expand Eligibility for the Streamlined CRA Exam

Dear Mr. Feldman:

I support the FDIC’s proposal to make changes to CRA evaluations that would increase the small institutions threshold from $250 million to $500 million. Our banks had received outstanding CRA ratings since this law was passed until Western Commerce Bank, Carlsbad, New Mexico, exceeded $250 million in assets.

In communities our size it is almost impossible to find a qualified community investment. We purchased a CRA qualified mutual fund that will never benefit Eddy County in order to comply with the big bank rules.

Our bank operates the same now as we did at $100 million in assets. Our loan to deposit ration is 75% and over the years we have been the leader in small business loans, affordable housing, small farm lending, etc.

At our last CRA exam, the FDIC folks felt sorry for us because they know how important this rating is to our people. We hadn’t changed; the business plan hadn’t changed; we just grew a little too much.

I have been a New Mexico state Senator for the past 12 years and understand all too well about pressure groups. I also understand the bank’s responsibility to our communities. Years ago, I was the Federal Reserve’s tame CRA advocate. When I spoke at meetings, I would encourage bankers to view CRA as a marketing plan. Everyone in our communities needs the same thing: affordable housing, transportation, etc. Just the cost is different.

I believe lending is the most important investment we make. Who, where, how much is not hard to tell and prove we are doing our job. I believe the same rules should be applied to all community banks. I understand the examiners need objective goals to refer to and I believe the under $250 million exam rules to that. By easing the regulatory burden, it will make it easier for community banks like Western Commerce to continue to provide community service to local communities that few other financial service providers are willing to do.

I still believe CRA is a good and necessary law as long as we can use some common sense.

Sincerely,

Don Kidd

Last Updated 10/04/2004 regs@fdic.gov

Last Updated: August 4, 2024