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RELIANCE SAVINGS BANK From: Barton Hann [mailto:bhann@reliancebank.com]
Sent: Wednesday, September 08, 2004 12:18 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50
Barton Hann
VP/Risk Management
Reliance Savings Bank
1119 12th St.
Altoona, PA 16601
September 8, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Robert Feldman:
As a community banker, I am pleased to comment in support of the
proposal issued by the FDIC that would amend the definition of a small
institution to be a bank that is under $1 billion in assets. I believe
that this change will provide much needed regulatory burden relief for
me and other community bankers. It seems that every week there is a new
or additional regulation with which we must comply. This is one example
of regulatory burden relief that will really make a difference. I would
much rather use the limited resources available to my bank to serve my
community than to collect and maintain data and documents to prove to
examiners that I am meeting the needs of my community.
Reliance Savings Bank is a mutually owned, community bank located in
central Pennsylvania, with approximately 73 full-time equivalent
employees. Our bank has assets of approximately $260 million, which
would make us ineligible to be classified as a small bank under the
current CRA standards.
Compliance with the Community Reinvestment Act is something we take
very seriously at our bank. We don’t just believe it is the right thing
to do; we believe it is the right business thing to do. No community
bank can survive and compete without meeting the needs of its customers
and communities. We believe in our community and in our customers and
want to work with them to provide products and services that best meet
their credit needs. We do not need a complicated examination process to
show that we are complying with the law.
It is absurd to think that a bank thousands of times larger than my
own community bank should be examined using the same procedures. I
strongly urge you to amend the definition of a small bank for CRA
purposes to be an institution with less than $1 billion in assets,
regardless of whether the bank is part of a holding company. This is a
good proposal and is the right thing to do.
Thank you for considering my views.
Sincerely,
H. Barton Hann, VP/Risk Mgmt.
VP/Risk Management
Reliance Savings Bank
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