JERSEY SHORE STATE BANK
August 31,
2004
Robert E. Feldman, Executive Secretary
Federal Deposit Insurance
Corporation
550 17th Street NW
Washington, DC 20429
RE: FDIC RIN #3064-AC50 Comments/Legal ESS
Dear Mr. Feldman:
The proposed rulemaking for CRA is a welcome foray into improving
possibilities for community development activities, although it is
somewhat anticlimactic in that it fails to effectively define the
proposed system for assigning credits under the proposed ceilings.
Certainly the proposal to move the large bank definition to over
$1 billion in assets is timely and necessary. However, it offers
no changes to banks over $1 billion in assets, while providing very
little in the way of relief for banks $250 million to $1 billion.
The current rules already use the same criteria to assess the effectiveness
of these banks' performance, with the exception of the proposal to
expand the definition of community development to encompass those
activities that benefit rural areas. While this will improve the
ability of small rural institutions to make better use of available
resources for their community development purposes, it is unclear
how it will benefit urban institutions and others similarly situated.
Perhaps the final rule could include additional credit for investments
or services for these institutions, due to their direct competition
with larger institutions for these activities.
With regard
to the definition of "rural", perhaps those
areas designated by the Rural Housing Service of the United States
Department of Agriculture as eligible for RHS financing would be
adequate or designate "rural" census tracts from time to
time, allowing for current data to suffice for the determination.
Thank you for your consideration of our comments.
Sincerely,
Ronal A. Walko
President
John R. Frey
Chief Compliance Officer
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