FDIC Federal Register Citations

Union Bank Company

From: Lehman, Gene [mailto:glehman@TheUBank.com]
Sent: Friday, September 17, 2004 1:15 PM
To: Comments
Cc: psmith@aba.com
Subject: FDIC CRA Proposal

September 17, 2004
Federal Deposit Insurance Corporation

To Whom It May Concern:
We 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.

As a rural bank, we 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.

As a community bank, our success is firmly tied to the success of the communities we serve. We believe that community banks should be required to help meet the credit needs of their entire communities and should continue to be so evaluated by their regulator.

Anything that the FDIC can do to reduce regulatory burden and the costly overhead required to comply with that burden will directly benefit the community banking industry's attempt to generate profits and increase capital thereby reducing risk to the deposit insurance fund. Slow-growth rural communities are especially vulnerable to price competition from less regulated out of market non-bank specialty shops such as mortgage brokers, credit card lenders, captive finance companies, regional credit unions, etc. The ability to continually layer new compliance overhead on a stagnant earning asset base is quantifiable and limited. Regulatory excess contributes to the consolidation trend in banking, thereby reducing community employment and responsiveness to community credit needs.

Thank you for you efforts on our behalf.

Sincerely,
E. Eugene Lehman,
President The Union Bank Company, Columbus Grove, Ohio