Bank of Wisconsin
Dells
From: Gary Gilliland [mailto:jleeg@dellsbank.com]
Sent: Friday, September 17, 2004 2:28 PM
To: Comments
Subject: Streamlined CRA Exam; RIN number 3064-AC50
Gary Gilliland
PO Box 490
Wisconsin Dells, WI 53965-0490
September 17, 2004
Comments to FDIC
Dear Comments to FDIC:
As a community banker, I join my fellow community bankers throughout
the
nation in strong support of the FDIC's proposal to increase the asset
size
limit of banks eligible for the streamlined small-bank CRA examination.
I
also strongly support the elimination of the separate holding company
qualification.
The proposal will greatly alleviate unnecessary paperwork and examination
burden without weakening our commitment to reinvest in our communities.
Reinvesting in our communities is something we do everyday as a matter
of
good business. My community bank will not long survive if my local
community doesn't thrive, and that means my bank must be responsive
to
community needs and promote and support community and economic
development.
Making it less burdensome to undergo a CRA exam by expanding eligibility
for the streamlined exam will not change the way my bank does business.
In fact, it will free up human and financial resources that can be
redirected to the community and used to make loans and provide other
services.
It is important to remember that the streamlined CRA exam is not
an
exemption from CRA. It is a more cost effective and efficient CRA
exam.
Banks subject to the simplified CRA exam are still fully obligated
to
comply with CRA. Just as now, community banks would continue to be
examined to ensure they lend to all segments of their communities,
including low- and moderate-income individuals and neighborhoods.
It just
doesn't make sense and is inequitable to evaluate a $500 million
or $1
billion bank using the same exam procedures as for $100 billion or
$500
billion bank.
In my opinion, our bank would be better off trying to truly reinvest
dollars locally to support our own market area rather than spending
resources trying to find "qualified investments" just to
satisfy a
requirement of the large bank CRA exam. Such investments might be
hard to
find anyway. For this reason, I find that the FDIC's proposed community
development requirement for banks between $250 million and $1 billion
is
more flexible and more appropriate than the large bank investment
test.
The advantage to this proposal is that it continues to focus on community
development, but considers investments, lending and services. It
would
let community banks pursue community development activities that
both meet
the local community's needs and make sense in light of the bank's
strategic strengths.
Similarly, the proposal will help rural banks meet the special needs
of
their communities by expanding the definition of "community
development"
so that it includes activities that benefit rural residents in addition
to
low- and moderate-income individuals. Rural banks are frequently
called
upon to support needed economic or infrastructure development such
as
school construction, revitalizing Main Street, or loans that help
create
needed or better-paying jobs. These activities should not be ineligible
for CRA credit because they do not benefit only low- or moderate-income
individuals.
The FDIC's proposed changes to CRA are needed to help alleviate
regulatory
burden. By easing regulatory burden, it will make it easier for community
banks like mine to continue to provide committed service to local
communities that few other financial service providers are willing
to do.
Thank you for considering my views.
Sincerely,
Gary L. Gilliland,
Chairman, President & CEO of Bank of Wisconsin
Dells
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