Voyager Financial Services Corporation
September 14, 2004
Robert E. Feldman
Attn: Comments / Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW.
Washington, DC 20429
RE: RIN number 3064-AC50
Dear Mr. Feldman:
Thank you for the opportunity
to comment on the proposed revisions to 12 CFR 345 implementing
the Community Reinvestment Act (CRA).
The change in the definition of “small bank” to raise
the asset size threshold to $1 billion is of particular interest
to us. In total our holding company has over $500 million in assets,
approximately $490 million is devoted to Voyager Bank. We have five
offices between our bank and mortgage company. All but one is located
in the metro areas of Minneapolis and St. Paul. A majority of the
bank’s customer base is commercial, but we do have a fair amount
of consumer clients.
We strongly support the
FDIC’s proposal to increase the asset
size of banks eligible for the small bank CRA examination to $1 billion.
Banks’ regulatory burden has increased significantly over the
past few years with the passage of such laws as the Gramm-Leach-Bliley
Act, the USA PATRIOT Act, HMDA 2004, the FACT Act and the Check 21
Act. While banks understand the need for banking regulations, community
banks find complying with them especially burdensome. The data collection
piece of “large bank” CRA makes up a significant chunk
of this weight. Changing the asset threshold to $1 billion will decrease
the regulatory burden for many community banks, leaving more time
for bank employees to meet the credit needs of their community.
The mandatory community
development criterion for banks with assets greater than $250 million,
as an additional component of small bank
standards is not unduly burdensome and would be acceptable to us.
Although this is the first year in which we are considered a “large
bank” for CRA purposes, our opinion is that the investment
and services tests do not require a large amount of additional employee
time. Our employees are already very involved in our communities,
and this is reflected in our number of qualified services. In addition,
we’ve created a relationship that allows us to make qualified
investments with very little difficulty. We understand, however,
that this is not the case for many of our community bank peers.
In conclusion, we firmly support raising the small bank threshold.
Thank you for the opportunity to comment on this important proposal.
Sincerely,
Brenda Sonnek, CRCM, CCBIA
Director of Internal Audit & Compliance, SVP
Voyager Financial Services Corporation
775 Prairie Center Drive
Eden Prairie, MN 55344
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