| Bank of Wisconsin Dells April 2, 2004
Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC 20429-0001
Attn: Comment Section
RE: CRA Proposal
Dear Sir,
I have been following with interest the current regulation proposal
to increase the asset size of banks eligible for the small bank
streamlined Community Reinvestment Act (CRA) examination from $250
million to $500 million and also eliminate the holding company size
limit, which is currently $1 billion. As President and Chief Executive
Officer of Bank of Wisconsin Dells, a $260 million bank located in
Wisconsin Dells in the south central part of the state, I strongly
endorse this Federal proposal because it would greatly reduce regulatory
burden.
During this critical time for our economy, it is important for our
sales people and loan officers to focus on developing business for the
bank, not spending time documenting procedures and doing paperwork. We
do not have the resources like the larger banks have for compliance
issues like this. Even if we had the resources available to devote to
CRA compliance, it would be resources not available for meeting the
credit needs of the community. The small bank CRA examination process
was an excellent innovation.
To really be fair, banks should be evaluated on the results in their
communities and be measured against their peers, not banks hundreds of
times their size. The proposed change recognizes that it is not right to
assess the CRA performance of a $260 million bank like mine with the
same exam procedures used for a $500 billion bank. While I feel the
proposed increase is a good first step, the size of banks eligible for
the small-bank streamlined exam really should be even higher, possible
$1 billion.
One thing seems very ironic to me. The community activists seem
oblivious to the costs and burden of regulations, yet they object to
bank mergers that remove the local bank from the community. This is
contradictory. If these groups want their local banks to remain in the
community where they have better access to decision-makers, they must
recognize that regulatory burdens are strangling smaller institutions
and putting them at a competitive disadvantage.
In summary, I believe that this change is an important first step to
reducing regulatory burden. While community banks still must comply with
the requirements of CRA (and should), this increase in size will
eliminate some of the most problematic and burdensome elements of the
current regulation. Finally, I would like to urge the agencies to
seriously consider raising the size of banks eligible for the
streamlined exam to at least $1 billion or possibly a little higher in
assets, to better reflect the current demographics of the banking
industry. This would allow us to grow and expand without further
regulatory burdens. Thank you for listening to my views.
Sincerely
Gary L. Gilliland
Chairman, President/CEO
Bank of Wisconsin Dells
716 Superior St.
Wisconsin Dells, WI 53965
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