Katahdin
Trust Company
From: Bonnie Foster [mailto:b.foster@katahdintrust.com]
Sent: Friday, September 17, 2004 1:57 PM
To: Comments
Cc: psmith@aba.com
Subject: RIN No. 3064-AC50
I am a Senior
Vice President of Retail Services of Katahdin Trust Company, located
in Houlton,
Maine. Houlton is a small community
of 6,800 and our entire market area of the bank has a population
of less than 75,000. Our market area encompasses over 6,500 square
miles and is completely rural. My bank size is $328 million and
just a couple of years ago came under the big bank criteria when
we passed the $250 million threshold. I am writing to strongly
support the FDIC’s proposal to raise the threshold for the
streamlined small bank CRA examination to $1 billion without regard
to the size of the bank’s holding company. This would greatly
relieve the regulatory burden imposed on many small banks such
as my own under the current regulation, which are required to meet
the standards imposed on the nation’s largest $1 trillion
banks. I understand that this is not an exemption from CRA and
that my bank would still have to help meet the credit needs of
its entire community and be evaluated by my regulator. However,
I believe that this would lower my current regulatory burden.
I also support the addition of a community development criterion
to the small bank examination for larger community banks. It appears
to be a significant improvement over the investment test. However,
I urge the FDIC to adopt its original $500 million threshold for
small banks without a CD criterion and only apply the new CD criterion
to community banks greater than $500 million up to $1 billion. Banks
under $500 million now hold about the same percent of overall industry
assets as community banks under $250 million did a decade ago when
the revised CRA regulations were adopted, so this adjustment in the
CRA threshold is appropriate. As FDIC examiners know, it has proven
extremely difficult for small banks, especially those in rural areas,
to find appropriate CRA qualified investments in their communities.
Many small banks have had to make regional or statewide investments
that are extremely unlikely to ever benefit the banks’ own
communities. That was certainly not intent of Congress when it enacted
CRA.
An additional
reason to support the FDIC’s CD criterion is
that it significantly reduces the current regulation’s “cliff
effect.” Today, when a small bank goes over $250 million, it
must completely reorganize its CRA program and begin a massive new
reporting, monitoring and
investment program. If the FDIC adopts its proposal, a state nonmember
bank would move from the small bank examination to an expanded but
still streamlined small bank examination, with the flexibility to
mix Community Development loans, services and investments to meet
the new CD criterion. This would be far more appropriate to the size
of the bank, and far better than subjecting the community bank to
the same large bank examination that applies to $1 trillion banks.
This more graduated transition to the large bank examination is a
significant improvement over the current regulation.
I strongly oppose making the CD criterion a separate test from the
bank’s overall CRA evaluation. For a community bank, CD lending
is not significantly different from the provision of credit to the
entire community. The current small bank test considers the institution’s
overall lending in its community. The addition of a category of CD
lending (and services to aid lending and investments as a substitute
for lending) fits well within the concept of serving the whole community.
A separate test would create an additional CD obligation and regulatory
burden that would erode the benefit of the streamlined exam.
I strongly support
the FDIC’s proposal to change the definition
of “community development” from only focusing on low-
and moderate-income area residents to including rural residents.
I think that this change in the definition will go a long way toward
eliminating the current distortions in the regulation. We caution
the FDIC to provide a definition of “rural” that will
not be subject to misuse to favor just affluent residents of rural
areas.
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. I will be happy
to discuss these issues further with you, if that would be helpful.
Bonnie C. Foster
Senior Vice President Retail Services
Katahdin Trust Company
P. O. Box 36
Houlton, Maine 04730
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