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Community Bank of Marion County
April 5, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D.C. 20429
RE: Proposed Revisions to the Community Reinvestment Act Regulations
Dear Robert E. Feldman,
As a community banker, I strongly endorse the federal bank
regulator’s proposal to increase the asset size of banks eligible for
the small bank streamlined Community Reinvestment Act (CRA) examination
from $250 million to $500 million and elimination of the holding company
size limit (currently $1 billion). This proposal will greatly reduce
regulatory burden. I am the President of Community Bank of Marion
County, a $213 million bank located in Ocala, Florida.
The small bank CRA examination process was an excellent innovation.
As a community banker, I applaud the agencies for recognizing that it is
time to expand this critical burden reduction benefit to larger
community banks. At this critical time for the economy, this will allow
more community banks to focus on what they do best – fueling America’s
local economies. When a bank must comply with the requirements of the
large bank CRA evaluation process, the costs and burdens increase
dramatically. And the resources devoted to CRA compliance are resources
not available for meeting the credit demands of the community. For
example in my bank, while we are the largest community bank in our
assessment area, increasing the asset size requirement would place more
burden and concern on trying to collect and report the additional
information by weighing the advantages of getting a community
development loan on our books before another bank did. This would leave
us less time to devote to working more personally towards helping areas
and businesses that currently bank with us in our community, and trying
to work towards better programs to assist/help other new people and
businesses in our assessment area. Our bank is very active in community
involvement, which I believe would be lost if our bank focused on the
large bank CRA requirements, and the whole purpose of being a small bank
would change. The additional cost of the large bank reporting burden
under CRA for our bank is estimated to be $100,000 per year.
Adjusting the asset size limit also more accurately reflects
significant changes and consolidation within the banking industry in the
last 10 years. To be fair, banks should be evaluated against their
peers, not banks hundreds of times their size. The proposed change
recognizes that it’s not right to assess the CRA performance of a $500
million bank or a $1 billion bank with the same exam procedures used for
a $500 billion bank. Large banks now stretch from coast-to-coast with
assets in the hundreds of billions of dollars. It is not fair to rate a
community bank using the same CRA examination. And, while the proposed
increase is a good first step, the size of the banks eligible for the
small bank streamlined CRA examination should be increased to $2
billion, or at a minimum, $1 billion.
Ironically, community activists seem oblivious to the costs and
burdens. And yet, they object to bank mergers that remove the local bank
from the community. This is contradictory. If community groups want to
keep the local banks in the community where they have better access to
decision-makers, they must recognize that regulatory burdens are
strangling smaller institutions and forcing them to consider selling to
larger institutions that can better manage the burdens.
Increasing the size of banks eligible for the small bank streamlined
CRA examination does not relieve banks from CRA responsibilities. Since
the survival of many community banks is closely intertwined with the
success and viability of their communities, the increase will merely
eliminate some of the more burdensome requirements.
In summary, I believe that increasing the asset-size of banks
eligible for the small bank streamlined CRA examination process is an
important first step to reducing regulatory burden. I also support
eliminating the separate holding company qualification for the
streamlined examination, since it places small community banks that are
part of a larger holding company at a disadvantage to their peers. While
community banks still must comply with the general requirements of CRA,
this change will eliminate some of the more problematic and burdensome
elements of the current CRA regulation form community banks that are
drowning in regulatory red-tape. I also urge the agencies to seriously
consider raising the size of banks eligible for the streamlined
examination to $2 billion or, at least, $1 billion in assets to better
reflect the current demographics of the banking industry.
Sincerely,
Hugh F. Dailey
President and C.E.O.
Community Bank of Marion County
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