From: Robert L. McKean
Sent: Friday, February 15, 2002 8:29 PM
To: Comments
Subject: Minority-Owned Depository Instutitions Policy Statement
Mr. Robert E. Feldman, Exececutive Secretary
Comments/OES
FDIC
550 17th St. NW
Washington, D.C. 20429
VIA EMAIL
Dear Mr. Feldman:
I am responding to the request for comments regarding the proposed revisions to the FDIC
Policy STatement on Minority-Owned Depository Institutions.
Overall, I believe the policy revisions represent a progressive step that will benefit the
community of FDIC-insured institions that are minority held, and that this will be a
positive move for the agency.
I would recommend a couple of modest changes from the draft proposal, as follows:
1. Eligibility
should be consistent with US Treasury's Minority Bank Deposit Program (MBDP), and the FDIC
should accept Treasury's certification in that regard. This would eliminate redundant
certification procedures for the affected institutions and streamline certification for
the agencies.
2. The requirement of
certain reporting by the designated institutions should be carefully examined, and created
to mirror existing reporting requirements of the Treasury Program (s) (MBDP or Community
Development Financial Institutions Fund, (CDFI)). Most of these institutions are already
over burdened with reporting, and it would be counterproductive in many cases to add
additional reporting burdens.
3. I would further
encourage the FDIC to adopt an "advisory board" of minority bank officials to
provide additional guidance to the agency in administering this program. One of the
sources of such a board may be the National Bankers Association (Norma Alexander Hart,
President; 1513 P Street NW; Washington, DC; 202-588-5432)
4. Additional
information on the type and level of technical assistance to be provided would be helpful
in evaluating the proposed changes. I would also encourage the agency to be certain that
the designated National and Regional Coordinators are directed to be proactive in seeking
out minority institutions and offering the technical assistance being proposed, as well as
to create an atmosphere of two-way dialog with them and the NBA to determine what kinds of
assistance would be most beneficial.
5. It would be
important to proactively seek out qualified minority institutions and individuals that may
have an interest in acquiring a minority-owned institutions, and to frequently update that
list (3-4 times per year).
Thank you for the opportunity to comment.
Sincerely,
Robert L. McKean
President and Chief Executive Officer
Albina Community Bank
2002 NE Martin Luther King Jr. Blvd.
Portland, Oregon 97212
(503) 288-7280
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