FDIC Federal Register Citations

Roselle Savings Bank

October 13, 2004

Mr. Robert E. Feldman
Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Dear Mr. Feldman:

As a community banker, I would like to comment about the proposal issued by the FDIC that would amend the definition of a "small" institution from under $250 million in assets to under $1 billion in assets. I support the change and believe that this change will provide regulatory burden relief for community banks that is much needed.

Roselle Savings Bank is a state chartered mutual institution in New Jersey. We are about $408 million in assets with 4 offices. We currently employ about 40 full and part time employees.

It seems so frequently now that there are new or additional regulations with which we must comply. The newly proposed CRA amendment is an excellent example of regulatory burden relief that could really make a positive difference. Our Board and management would much rather use the lir'ited resources available to our bank to serve our community instead of to collect and maintain data and documents to prove to examiners that we are meeting the needs of our community.

As a 400 million dollar institution, we truly believe our peers are other institutions in the 250 to 700 million dollar range, not institutions with many billions in assets. We just do not have the same resources as the mega banks. It is not realistic to think that a bank thousands of times larger than our 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. Compliance with the Community Reinvestment Act is something we take seriously at our bank. We are a fairly successful community bank, and 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 and deposit needs. We do not think a complicated examination process should be necessary to show that we are complying with the law.

The proposed changes to CRA are certainly needed to help alleviate regulatory burden. Without changes such as this, many of our community banks, such as mine, will not be able to maintain their existence because of the increasing regulatory burden, and will find themselves in the position of having to merge. The loss of a local bank can be a blow to a community. Easing regulatory burden will make it easier for community banks to provide committed service to local communities that few larger institutions are willing to do.

I am sure my letter is just one of many you are receiving from community bankers, so I wish to thank you for considering my views.

Very truly yours,
Jill G. Schafhauser, President
Chief Executive Of icer