First
Federal fsb
From: Larry Romo
Sent: Thursday, September 09, 2004 5:19 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50
Larry Romo
CRA Director
First Federal fsb
201 Main St S
Hutchinson, MN 55350
September 9, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Robert Feldman:
As being part of a community bank, I am pleased to comment in support
of
the proposal issued by the FDIC that would amend the definition of
a small
institution to be a bank that is under $1 billion in assets. This
change
will provide much needed regulatory relief for First Federal fsb
and other
Community Bankers and will result not in less service to our customers,
but more. We would much rather use the limited resources that are
available to our bank to serve our community rather than to collect
and
maintain data and documents to prove to examiners that we are meeting
the
needs of our community.
We take compliance with the Community Reinvestment Act very seriously
at
First Federal fsb and frankly have taken it seriously long before
the CRA
Act was even passed. We learned long ago, along with other Community
Banks, that serving our entire community and all of our customers
with
products and credit services that serve their needs is good business.
We
continue in our efforts to provide even more and better services
as people
new to our area and new to our country become part of our community.
For
anyone to make the assertion that small institutions will not serve
their
communities without stringent, intense and costly examinations is
absurd
and has absolutely no basis in fact.
First Federal fsb has $505,192,000 in assets, and we have 230 employees,
181 full-time and 49 part-time. Our community consists of all or
part of
8 counties including both metropolitan and rural areas. Every person
in
this area is important to our bank, and our services are targeted
to serve
every single one of them. There is not one inch of land in this area
that
we will not consider a mortgage on with one of the many affordable
loan
programs that we offer. Only those with a self-serving agenda, other
than
service to our communities would make such statements. 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 or not. This is a good proposal
and the
right thing to do.
Thank you for considering my views.
Sincerely,
Larry Romo, CRA Director
CRA Director
First Federal fsb
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