FDIC Federal Register Citations

September 20, 2004

Comments for the FDIC CRA Proposal

Re: FDIC CRA Proposal

To Whom It May Concern:

The purpose of this letter is to state my strong and complete support of the FDIC’s proposal to increase the Community Reinvestment Act threshold for small banks to $1 billion without regard to the size of the bank’s holding company. I am the President of Park Bank in Milwaukee, Wisconsin, a commercial bank with total assets of approximately $600 million. The increase in the subject asset size threshold would significantly relieve the regulatory burden imposed upon banks our size, and allow us more time and resources to do what we do best, supporting neighborhoods and businesses within our local community. My belief is that this proposal, if enacted, would put in place standards, which would more readily allow the FDIC to gauge the responsiveness of banks to their communities when they are in the asset range of $250 million to $1 billion.

The current CRA examination process places Park Bank of Milwaukee, Wisconsin into the same category, and thus having to meet the same standards, as imposed on the nation’s largest banks, which have over $1 trillion in assets. Some of these banks are thousands of times our size. The current three-fold CRA examination process does not allow a bank our size to be properly evaluated. Trying to meet these “large” bank standards is an immense and costly regulatory burden on small banks. We whole-heartedly support the requirement that community banks would need to continue to meet the credit needs of their entire communities, and be so evaluated by our regulators.

Park Bank has always been recognized for significant effort within the lending and service tests of the present CRA examination process. As a matter of note, as of industry data for the period ended March 31, 2004, Park Bank had the 11th largest commercial and industrial loan portfolio of any community bank in the entire United States. The criteria for this ranking involved community banks with under $1 billion in assets having more than 50% of those assets in outstanding loans and not more than 25% of its loan portfolio in credit card loans. Similarly, our holding company, Bankmanagers Corp., held the 190th ranking in the entire country as of March 31, 2004 in terms of the largest commercial and industrial loan portfolios ranked by holding company. This places Bankmanagers Corp. in the top 2.4% of all commercial bank holding companies in the country in terms of generating a commercial and industrial loan portfolio. It is obvious that we strongly believe in the support of our community responsibilities through our lending practices as well as the service of our employees to our community. The present investment test as imposed on banks classified as “large” under current CRA examination procedures is structured in a way which makes it virtually impossible for us to attain a satisfactory rating or higher. This is indicative of being unfairly compared to banks hundreds and thousands of times our size.

I urge your support of the FDIC’s proposal to increase the Community Reinvestment Act threshold for the streamlined small bank CRA examination to $1 billion from the current level of $250 million in assets. Resources saved from this change will allow us to better meet the needs of our community, and to continue to enhance our performance under other regulatory measures such as the Bank Secrecy Act, the USA Patriot Act and our Customer Identification Program. Your help in supporting this proposal would be greatly appreciated.

If you have any questions, I can be contacted directly at 414-270-3207.

Very truly yours,

PARK BANK
P. Michael Mahoney
Chairman of the Board and President