FDIC Federal Register Citations

Cameron State Bank

October 15, 2004

Federal Deposit Insurance Corporation
Robert E. Feldman, Executive Secretary
Attn: Comments/Legal ESS
550 17th Street, NW
Washington, DC 20429-0002

Re: Proposed Amendments to the CRA

Dear Sir:

It has been brought to the attention of our financial institution that your agency, through Fl L-108-2004, has requested comments on the proposed amendments to the Community Reinvestment Act. As an Assistant Vice-President of a community bank, I would like to comment on the proposed amendment that would change the definition of a small institution from one with total assets of $250 million to $1 billion.

Since our financial institution was classified as a "large bank" under the CRA, we have had to deal with the increased regulatory burden concerning the data collection and reporting on small business, small farm, and community development loans. Since our institution makes the majority of its loans inside our assessment area, this collection and reporting becomes a burdensome task.

An additional issue involves the process of the CRA examination. It is difficult for a community bank such as ours to attain a satisfactory rating under the large bank CRA investment test. Smaller institutions are at a disadvantage when competing for suitable investments against billion dollar regional and national banks; they have unlimited resources to obtain those investments and will stop at nothing to get them, leaving the smaller institutions at an unfair advantage during an exam.

Our institution is in favor of changing the definition of a small institution to one with up to $1 billion without regard to the holding company assets.

Thank you for your time and consideration.

Sincerely,
Janet McNeese
Assistant Vice-President