FDIC Federal Register Citations

Capitol Bancorp Limited


March 18, 2004

Re: 12 CFR Part 228
Regulation BB;
Docket No. R-1181

Dear Sirs/Madams:

This comment letter is submitted on behalf of Capitol Bancorp Limited, a $2.7 billion bank development company, and its thirty individually chartered banks located in Arizona, California, Indiana, Michigan, Nevada, and New Mexico. These thirty community banks have total assets ranging from $329 million to $27 million.

Due to the current “small bank” definition including the holding company reference, all thirty of the above-mentioned banks are considered “large banks”. We have experienced “Large Bank” CRA Evaluations at banks less than two years old who have not yet even reached the Home Mortgage Disclosure Act reporting threshold. It is difficult for smaller sized banks to satisfactorily pass the investment test and almost impossible for those banks to be in a “leadership position” while offering community development loans, investments, and services. Therefore, our organization fully appreciates and supports the proposed amendments to the Regulation BB “small bank” definition. Furthermore, we commend the agencies’ efforts at reducing the regulatory burden at smaller sized institutions.

Thank you for the opportunity to comment.

Sincerely,

Nancy Schoolman, CRCM
Vice President, Corporate Compliance Officer