FDIC Federal Register Citations

FARMERS STATE BANK

From: DOUG NEIGHBOR [mailto:Doug_Neighbor@fsbmail.net]
Sent: Monday, September 13, 2004 5:16 PM
To: Comments
Subject: RIN 3064-AC50

Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
500 17th Street NW
Washington, DC 20429

RE: Community Reinvestment Act Proposal
RIN 3064-AC50

Dear Mr. Feldman:

I am writing to support your proposal to increase the asset threshold for banks to qualify for the streamlined examination procedures under the Community Reinvestment Act.

I work for a community bank and do not feel that with seven locations my institution is comparable to banks with several hundred locations and billions of dollars in assets. It is extremely difficult for us to compete with billion-dollar institutions for qualified investments that meet the requirements under large bank CRA. The larger institutions have the money, manpower and technology to outbid us. Too many times the efforts we put forth to meet investment goals go unrecognized, as it is overshadowed by the performances of our billion-dollar “peers”.

Increasing the size of banks eligible for the small bank CRA exam will not relieve banks from CRA responsibilities. The growth and survival of the bank is intertwined with the growth and survival of the community. As a family owned, community bank, our attitudes towards supporting the communities in which we raise our families would remain unchanged. We would merely have a reduction in reporting requirements and costs, freeing up more time and money that could be better spent in the development of the community.

Today’s community banks are drowning in regulatory red tape, utilizing valuable resources to meet regulatory compliance mandates that could be put to much better use for economic and development purposes in the communities in which we live and work. Thank you for recognizing this and proposing the changes to the Community Reinvestment Act. If you have any questions in regards to these comments, please feel free to contact me.

Sincerely,

Douglas N. Neighbor