NEW JERSEY LEAGUE OF COMMUNITY BANKERS
April 2, 2004
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re:
Community Reinvestment Act Regulations – No. 2004-04
69 FR 5729 (February 6, 2004)
Dear Mr. Feldman:
The
New Jersey League of Community Bankers? (“the League”)
is pleased to comment on the proposal to revise and update the
Community Reinvestment Act (“CRA”) regulations.
The
League strongly supports the proposed revisions to the CRA
regulations and urges the federal
banking regulatory agencies
to further reduce the regulatory burden on smaller institutions
by amending the definition of “small institution” to
mean an institution with total assets of less than $1 billion,
without regard to any holding company assets.
The small institution performance standards under the CRA regulations
recognize that smaller institutions do not have the resources
that larger institutions have to collect the data necessary for
the reporting required of larger institutions. Smaller institutions
also do not have as many options open to them for meeting the
investment test. League members note that large institutions,
because of the size of the investments they can make, have more
opportunities open to them for investments that qualify for CRA
credit.
Raising the threshold for institutions that must comply with
the requirements for large institutions would be a major step
in reducing the regulatory burden for smaller institutions. Our
members are community banks that strongly believe in reinvesting
in the communities they serve. Raising the threshold will not
dampen that commitment to their communities.
The League also supports the provisions of the proposed regulation
that would take evidence of discriminatory or other illegal credit
practices into account in an agency’s evaluation of an
institution’s CRA performance. The League believes that
even one predatory loan is one too many.
Sincerely,
James R. Silkensen, Executive Vice President
New Jersey League of Community Bankers
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