BANK OF AKRON
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal
ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
August 26, 2004
Dear Mr. Feldman:
The following comments are offered in response to the notice of
proposed rulemaking, Vol. 6, No. 161 issued Friday, August 20, 2004
regarding Community Reinvestment Act (CRA).
The Bank of Akron wholly endorses the FDIC's efforts to reduce regulatory
burden and would encourage the FDIC to expand these efforts further.
Specific to the proposed changes to the Community Reinvestment Act
the proposed change in definition of small bank to an asset size
of $1 billion is a positive step. This step should not be diluted
by adding additional criteria for those banks with assets between
$250 million and $1 billion.
The concerns
of community organ1zations are, in fact misplaced. Small community
banks cannot
survive without the support of the community
it serves. This support can only be gleaned by providing value added
services to all segments of the community, not least of which is
the low to moderate income sector. While lending to this sector is
understandably the most important criteria for community reinvestment,
greater consideration should be given to all aspects of community
involvement and the bank's total commitment to the community given
due regard when measuring "community development".
While a clean formula for the measurement of community development
activities is desirable, it is also impractical due to the differences
in the communities each bank serves. This is highlighted by the proposed
addition of community development in rural communities. The ability
and willingness of a bank to make loans and provide support to efforts
to improve their assessment area, regardless of the principal business
activities are the key criteria What each bank must address is the
community's needs, whatever they may be. The FDIC's challenge is
to properly recognize those efforts in aggregate, not against (albeit
meaningful but) arbitrary criteria
Sincerely,
E. Peter Forrestel II
President
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