First
National Bank
From: Tom Pohlman
Sent: Monday, March 22, 2004 12:43 PM
To: Comments
Subject: Comments on CRA Revisions
Tom Pohlman
3117 Bayberry Rd
Ames, IA 50014
March 22, 2004
Dear Mr. Feldman
I am writing on behalf of First National Bank, a national bank located
in
Ames, Iowa. Our customer base is primarily middle income while our
lending activities are broad based and include commercial, consumer
and
real estate lending. Our current asset size is $385MM with a loan
portfolio of $175MM. We applaud and appreciate the proposed amendments
to the Community Reinvestment Act being made by the Office of Comptroller
of the Currency, Federal Reserve Board, Federal Deposit Insurance
Corporation and Office of Thrift Supervision, “the Agencies.” We
also
appreciate the Agencies’ recognition and understanding of the
challenges
faced by community banks in meeting the requirements of the ever-growing
number of compliance regulations.
Increasing the asset size of banks eligible for the small bank CRA
exam
from $250 million to $500 million and eliminating the holding company
size
limitations will go along way in reducing the regulatory burden of
many
small banks, including my institution. It is ridiculous to compare
a bank
with a few branch locations and total assets of $250 million to a
bank
with hundreds of locations and billions of dollars in assets under
the
same exam process. Small banks simply do not have the resources (money,
manpower, technology) to compete with these large institutions under
the
large bank test. To many times a community bank, that has served
its
local community well, is not afforded the recognition it deserves
simply
because it is compared with huge multi-million dollar organizations.
Just
as the community investment abilities of small and large banks differ,
so
do the needs of the small and large communities they serve. The ripple
affect of smaller dollar projects in a rural community may far outweigh
a
multi-million dollar investments’ impact a metropolitan area,
yet the
small community bank’s CRA rating often does not reflect this.
I also support the elimination of the bank holding company asset
size
threshold. Many banks maintain their own charter, management and
operational processes when purchased by a large holding company.
They
“
inherit” the regulatory requirements of the holding company
but do not
always benefit from the holding company’s resources for complying
with
these requirements.
Increasing the size of banks eligible for the small-bank streamlined
CRA
exam does not relieve banks from CRA responsibilities. The growth
and
survival of the bank is intertwined with the growth and survival
of the
community. The change merely reduces the reporting requirements and
costs
for small bank, freeing up more time and money that can be better
spent in
service to the community the bank is located.
Today’s
community banks are drowning in regulatory red tape, utilizing
valuable resources to meet regulatory compliance mandates that could
be
put to much better use for economic and community development purposes
in
the communities they serve. Thank you for recognizing this and proposing
the changes to the Community Reinvestment Act.
Sincerely,
Tom
Pohlman
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