Skip to main content
U.S. flag
An official website of the United States government
Dot gov
The .gov means it’s official. 
Federal government websites often end in .gov or .mil. Before sharing sensitive information, make sure you’re on a federal government site.
Https
The site is secure. 
The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely.
Federal Register Publications

FDIC Federal Register Citations



Home > Regulation & Examinations > Laws & Regulations > FDIC Federal Register Citations




FDIC Federal Register Citations

CITIZENS NATIONAL BANK IN WAXAHACHIE

From: Mark Singleton [mailto:mes3@cnbwax.com]
Sent: Thursday, September 16, 2004 8:25 AM
To: Comments
Cc: psmith@aba.com; George Singleton
Subject: increase the Community Reinvestment Act threshold for small banks to $1 billion

September 16, 2004

To whom it may concern:

I 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 small banks under the current regulation, which are required to meet the standards imposed on the nation’s largest $1 trillion banks. Community banks would still be required to help meet the credit needs of their entire communities and would continue to be so evaluated by their regulator.

I also strongly support the addition of a community development criterion to the small bank examination for larger community banks, but we believe the new community development (CD) criterion should be applied only to banks greater than $500 million up to $1 billion. Community banks up to $500 million now hold about the same percent of overall industry assets as community banks up to $250 million did a decade ago when the revised CRA regulations were adopted, so this adjustment in the CRA threshold is appropriate. As bankers and 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. This result certainly was not intended by Congress when it enacted CRA.

I strongly oppose making the CD criterion a separate test from the bank’s overall CRA evaluation. Such differentiation creates the impression that CD lending is different from the provision of credit to the entire community. The current small bank test considers the institution’s overall lending in its community. A separate test would create an additional CD obligation and regulatory burden, eroding the intent 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. This change will go a long way toward eliminating the current distortions in the regulations that result in a small rural bank being told to invest in regional affordable housing bonds for an urban area not in the bank’s community.

Sincerely;
Marvin E. Singleton III
President and CEO
Citizens National Bank in Waxahachie

Last Updated 09/29/2004 regs@fdic.gov

Last Updated: August 4, 2024