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via e-mail
AMERIMARK BANK February 25, 2004
Robert E. Feldman
Executive Secretary
Attention: Comments, Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429
Comments on FIL-15-2004 Proposed Amendments to the Community
Reinvestment Act
Dear Mr. Feldman:
AmeriMark Bank is a community bank which has approximately $160
million in assets. The Bank primarily serves the communities surrounding
its two full service branches and one drive-in and ATM convenience
center in the western and southwestern suburbs of Chicago, IL. We are
involved in our communities and believe that the current regulations for
CRA for “small institutions” are appropriate.
We agree that the threshold for a “small institution” should be
raised. We believe that the threshold for a “small institution” should
be financial institutions with total assets less than $1 billion. We
believe that the additional compliance costs for new personnel and
outside contractors, data collection, and reporting costs are very
significant and burdensome for institutions below $1 billion in assets.
These smaller institutions are involved in their communities and provide
the investment and credit for community development. The CRA regulations
should reflect the recent consolidation of the industry. The industry is
continuing to see a bar bell effect with mega banks on one end of the
spectrum and smaller banks on the other side with the medium sized
institutions merging or being bought by larger institutions.
The mega banks of CitiCorp, JP Morgan Chase/ Bank One, Bank America
and Wells Fargo have far more resources and impact on community
development than financial institutions with less than $1 billion in
assets. Financial institutions with $1 billion in assets or more have
many more branches and ability to serve entire metropolitan areas rather
than specific communities in a metropolitan area. The current regulation
ensures the “smaller institutions” are complying with CRA without
placing undue burden on the institution. We would recommend that the
threshold for “smaller institutions” be raised to financial institutions
with assets less than $1 billion in assets.
Sincerely,
Peter B. Stickler
Senior Vice President and Chief Financial Officer
AmeriMark Bank
305 West St Charles Road
Villa Park, IL 60181
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