FDIC Federal Register Citations

From: Jeff Ropiecki [mailto:ropiecki@capesb.com]
Sent: Tuesday, September 21, 2004 3:31 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50

Jeff Ropiecki
Vice President Sales and Marketing
Cape Savings Bank
225 N Main Street
Cape May Court House, NJ 08210

September 21, 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.

Cape Savings Bank is a mutual community savings bank, serving Atlantic and Cape May Counties in the State of New Jersey, with an asset size of $523,013,635, as of 8/31/04, with a full and part time employee base of approximately 140.

To accomplish our Mission of serving our community diligently with integrity and pride and support Cape May and Atlantic County non-profit and community development projects, Cape Savings Bank donates 8% of our after tax profits to non-profit organizations and community development projects, so long as our tier one leverage capital ratio is greater than 8%.

Our directors, officers, employees and officers participation in community events is encouraged and supported. In fact, during 2003, Cape Savings Bank logged over 1100 hours in volunteer activity. Year-to-date in 2004, over 600 hours have been accumulated. Cape Savings Bank is committed to fostering an attitude of mutual respect between the employees of Cape Savings Bank and the community.

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,
Jeff Ropiecki
609-465-5600
Vice President Sales and Marketing
Cape Savings Bank