FDIC Federal Register Citations

From: Judy Usitalo [mailto:jusitalo@snb-t.com]
Sent: Thursday, September 16, 2004 3:30 PM
To: Comments
Subject: CRA Proposal

The purpose of this email is 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. Currently, we smaller banks are expected to meet regulatory standards imposed upon the nation’s largest banks and this is not fair or rational. Our bank is in a rural area and finding appropriate CRA qualified investments is difficult. This results in smaller banks having to make regional or statewide investments that are unlikely to ever benefit our smaller communities. Certainly this is NOT what Congress had in mind when CRA was enacted. We also strongly oppose making the CD criterion a separate test from the bank’s overall CRA evaluation. 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.

We 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. It is time to turn the tables in fairness to small, rural community banks and not force them to invest in regional affordable housing bonds for an urban area and not in the bank’s own community.

Thank you for your consideration of our request.

Sincerely,

Judith M. Usitalo
Vice President
Superior National Bank & Trust Company