From: Neil Fruechte
Sent: Friday, September 10, 2004 2:26 PM
To: Comments
Subject: Streamlined CRA Exam; RIN number 3064-AC50
Neil Fruechte
217 9th St NE
Waseca, MN 56093-3337
September 10, 2004
Comments to FDIC
Dear Comments to FDIC:
As a community banker, I strongly 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.
I
understand that the streamlined CRA exam is not an exemption from
CRA.
It is a more cost effective and efficient CRA exam for us as a community
bank. It just doesn't make sense to evaluate a $500 million or $1
billion bank using the same exam procedures as for $100 billion or
$500
billion bank.
The proposal will help rural banks such as ours 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.
Thank you for allowing me to comment on this proposal.
Sincerely,
Neil N. Fruechte
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