FDIC Federal Register Citations

St. Louis County Economic Council

From: Owens, Patrick [mailto:POwens@stlouisco.com]
Sent: Thursday, October 14, 2004 10:29 AM
To: Comments
Subject: EGRPRA Burden Reduction

As a former bank examiner, I oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services in low-income communities.

I was a Consumer Compliance Bank examiner for 4 years and have now worked in community development for another 8 years. It is very clear that the Community Reinvestment Act has resulted in direct investment and services to low- to moderate-income (LMI) areas that would otherwise not have been given a second thought.

There is increasing pressure on the lending industry to get more from the bottom line. Lenders can do that if they educate themselves about how to make loans and investments in these under served areas. There is a largely untapped market there where educated lenders can and do make a profit.

To ease this restriction would remove the incentive for smaller banks to educate themselves how to serve these markets. Not only will this reduce the amount of competition for lending in the LMI areas, it will also damage the lending industry that has fewer and fewer competitors due to the cut-throat merger and acquisition climate.

Less competition means less banks to regulate. Isn't that a concern of each of the Federal regulatory agencies? I encourage the FDIC, Federal Reserve, OTS and the OCC to fully consider this proposal and the negative effects it will have on not only the LMI areas but the lending industry as a whole.


Patrick M. Owens
St. Louis County Economic Council
121 S. Meramec, Suite 900
St. Louis, Missouri 63105