Affinity Bank
March 31, 2004
Robert E. Feldman
Executive Secretary
Attn: Comments
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, D.C. 20429
Re: Proposed Revisions to the Community Reinvestment Act Regulations
Dear Mr. Feldman:
As a community banker, I strongly endorse the federal bank
regulators' joint proposal to increase the asset size of banks eligible
for the small bank streamlined Community Reinvestment Act (CRA)
examination from $250 million to $500 million. In fact, I believe that
this threshold should be increased to at least $1 billion.
The regulatory burden on small banks has continued to grow since the
CRA regulations were rewritten in 1995 and now include, among others,
new reporting requirements under HMDA, the USA Patriot Act and the Fair
Credit Reporting Act. The costs and burden associated with these
regulations keep community banks from concentrating on the business of
banking and on meeting the credit needs of our local communities.
Adjusting the asset size limit also more accurately reflects the
consolidation that has taken place within the banking industry over the
past ten years. Banks should be evaluated against banks within their
peer group, not banks hundreds of time their size. The proposed change
reflects that it is not fair to assess the CRA performance of a $500
million bank or a $1 billion bank with the same exam procedures used for
a $500 billion bank.
Increasing the size of banks eligible for the small-bank streamlined
CRA examination does not relieve banks from CRA responsibilities, it
merely eliminate some of the most burdensome requirements.
In summary, I believe that increasing the asset-size of banks
eligible for the small bank streamlined CRA examination process is an
important first step to reducing unnecessary regulatory burden and will
have only a small effect on the amount of total industry assets covered
by the large bank test.
Thank you for your consideration.
Sincerely,
Steven A. Ehrlich
Chairman, President and
Chief Executive Officer
Affinity Bank
1310 Broadcasting Road
Wyomissing, PA |
