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Farmers State Bank, Marion, IA
From: Diane Foltz
[mailto:Diane_Foltz@fsbmail.net]
Sent: Monday, April 05, 2004 10:23 AM
To: Comments
Subject: Feb. 06, 2004 - Joint Notice of proposed rulemaking
March 26, 2004
Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
500 17th Street NW
Washington, DC 20429
RE: Community Reinvestment Act Proposal
To whom it may concern:
I am writing on behalf of Farmers State Bank, a state-chartered,
non-member bank. We are located in Marion, Iowa and currently have an
asset size of $435 million. We appreciate the opportunity to comment on
the proposed amendments to the Community Reinvestment Act (CRA).
While we support your proposal to increase the asset size for banks
eligible to be examined under the CRA small bank test to $500 million,
we urge you to consider increasing that threshold to $1 billion. As a
financial institution growing towards the $500 million mark, we do not
feel that with seven locations we are comparable to banks with several
hundred locations and billions of dollars in assets. It is extremely
difficult for a bank of our size to compete with billion-dollar
institutions for qualified investments that meet the requirements under
large bank CRA. The larger institutions have the money, manpower and
technology to beat us to the punch every time. Too many times the effort
we put forth to meet investment goals goes unrecognized, as it is
overshadowed by the performances of our billion-dollar “peers”.
We also support the elimination of the bank holding company asset
size threshold. Many banks maintain their own charter, management and
operational processes when purchased by a large holding company. They
“inherit” the regulatory requirements of the holding company but do not
always benefit from the holding company’s resources for complying with
these requirements.
Increasing the size of banks eligible for the small bank CRA exam
does not relieve banks from CRA responsibilities. The growth and
survival of the bank is intertwined with the growth and survival of the
community. As a family owned, community bank, our attitudes towards
supporting the communities in which we raise our families would remain
unchanged. We would merely have a reduction in reporting requirements
and costs, freeing up more time and money that could be better spent in
the development of the community.
Today’s community banks are drowning in regulatory red tape,
utilizing valuable resources to meet regulatory compliance mandates that
could be put to much better use for economic and development purposes in
the communities in which we live and work. Thank you for recognizing
this and proposing the changes to the Community Reinvestment Act. If you
have any questions in regards to these comments, please feel free to
contact me.
Sincerely,
Diane M. Foltz
Compliance Officer
(319) 377-4891
dianefoltz@fsbmail.net
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