September 9, 2004
Comments to FDIC
Dear Comments to FDIC:
As a community banker, I join my fellow community bankers throughout
the
nation in strong support of the FDIC's proposal to increase the asset
size
limit of banks eligible for the streamlined small-bank CRA examination.
I
also strongly support the elimination of the separate holding company
qualification.
The proposal will greatly alleviate unnecessary paperwork and examination
burden without weakening our commitment to reinvest in our communities.
Reinvesting in our communities is something we do everyday as a matter
of
good business. My community bank will not long survive if my local
community doesn't thrive, and that means my bank must be responsive
to
community needs and promote and support community and economic
development.
Making it less burdensome to undergo a CRA exam by expanding eligibility
for the streamlined exam will not change the way my bank does business.
In fact, it will free up human and financial resources that can be
redirected to the community and used to make loans and provide other
services.
It is important to remember that the streamlined CRA exam is not
an
exemption from CRA. It is a more cost effective and efficient CRA
exam.
Banks subject to the simplified CRA exam are still fully obligated
to
comply with CRA. Just as now, community banks would continue to be
examined to ensure they lend to all segments of their communities,
including low- and moderate-income individuals and neighborhoods.
It just
doesn't make sense and is inequitable to evaluate a $500 million
or $1
billion bank using the same exam procedures as for $100 billion or
$500
billion bank.
One of the problems with the current large bank CRA exam is that
the
definition of "qualified investments" is too limited, and
qualified
investments can be difficult to find. As a result, many community
banks
(especially those in rural areas) have to invest in regional or statewide
mortgage bonds or housing bonds and the like to meet CRA requirements.
These investments may benefit other areas of the state or region,
but they
actually take resources away from the bank's local community. Community
banks and communities would be better off if the banks could truly
reinvest those dollars locally to support their own local economies
and
residents.
For this reason, I find that the FDIC's proposed community development
requirement for banks between $250 million and $1 billion is more
flexible
and more appropriate than the large bank investment test. The advantage
to this proposal is that it continues to focus on community development,
but considers investments, lending and services. It would let community
banks pursue community development activities that both meet the
local
community's needs and make sense in light of the bank's strategic
strengths.
Similarly, the proposal will help rural banks meet the special needs
of
their communities by expanding the definition of "community
development"
so that it includes activities that benefit rural residents in addition
to
low- and moderate-income individuals. Rural banks are frequently
called
upon to support needed economic or infrastructure development such
as
school construction, revitalizing Main Street, or loans that help
create
needed or better-paying jobs. These activities should not be ineligible
for CRA credit because they do not benefit only low- or moderate-income
individuals.
The FDIC's proposed changes to CRA are needed to help alleviate
regulatory
burden. Without changes such as this, more and more community banks
like
mine will find they cannot sustain independent existence because
of the
crushing regulatory burden, and will opt to sell out. For many small
towns and rural communities, the loss of the local bank is a major
blow to
the local community. By easing regulatory burden, it will make it
easier
for community banks like mine to continue to provide committed service
to
local communities that few other financial service providers are
willing
to do.
Thank you for considering my views.
Sincerely,
Susan Higgins, Albuquerque, NM
Rebeca Romero, Taos, NM
Steve Garrett,
Albuquerque, NM
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