NORTHPOINTE
BANK
From: Tom Sall [mailto:TOMS@npbank.com]
Sent: Tuesday, March 30, 2004 2:44 PM
To: Comments
Subject: Proposed CRA Amendments Comment
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
comments@fdic.gov
Re: Community Reinvestment Act Regulations
Dear Mr. Feldman:
I am the Compliance Officer for a $200 million bank located in Grand
Rapids, Michigan. I wish to voice my support for the federal bank
regulators' 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. I also support the elimination
of the $1 billion holding company size limit.
I am in favor
of this proposal because it will greatly reduce regulatory burden
and will
free up more resources for community banks to do
what they should be doing under CRA – meeting the credit needs
of their local communities. The proposed change also recognizes that
it's not right or fair to assess the CRA performance of a $500 million
bank with the same exam procedures used for a $500 billion bank.
Furthermore, I believe that the asset size limit, once it is increased
to $500 million, should be increased on an annual basis in the same
way that the asset threshold for Home Mortgage Disclosure Act reporting
is increased (under Federal Reserve Regulation C).
Increasing the asset size of banks eligible for the small-bank streamlined
CRA examinationwill not relieve banks from their CRA responsibilities.
On the contrary, since the survival of many community banks, including
Northpointe Bank, depends upon the success and viability of their
communities, the increase will merely eliminate some of the most
burdensome requirements.
Thank you.
Thomas Small
Vice President, Risk Mgt
Northpointe Bank
|
