WESTBANK
From: Amy Sheehan [mailto:sheehana@westbank-trust.com]
Sent: Wednesday, September 08, 2004 10:52 AM
To: Comments
Subject: RIN #3064-AC50
The proposed increase to the small bank threshold to $1.0 billion
would provide needed regulatory relief to mid-size community banks, many
of whom spend inordinate amounts of time collecting and reporting data
on small business lending. Depending on the computer system a bank has,
much of this data collection, while automated for the most part,
involves many manual gyrations to properly collect information on
renewals of lines of credit, among other types of commercial credits.
The removal of the separate Lending, Investment, and Service tests
would not negatively affect how banks perform in their communities; it
would actually result in more resources available to search out worthy
recipients of loans, services, and investments.
A separate Community Development Test, if developed properly, would
enable a bank to customize the way it best helps its constituents. As it
is now, banks are penalized for not having a certain number or level of
community development loans, investments, and services. Mid-size
community banks, many times, cannot compete with the larger regional
institutions in
affordable housing lending projects, many of which involve a bidding
process either with the organization itself or a larger entity, such as
the FHLB. The ability to customize the ways in which we help the low-
and moderate-income individuals and/or geographies in our assessment
areas would enable banks to work to their strengths. Also, it might be
prudent to allow for consideration of a bank's efforts in attempting to
meet the community development test parameters; for example, giving a
bank credit for a program that it put together to propose to a worthy
organization during a bidding process, even if the institution was not
ultimately chosen for the project. Banks spend a great deal of time,
when opportunities arise, putting together proposals for projects, many
of which never come to fruition.
Amy B. Sheehan
Senior Vice President
Compliance/CRA/BSA Officer
Westbank
225 Park Avenue
West Springfield, MA 01090
(413) 747-1385
(413) 731-8398 fax
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