FDIC Federal Register Citations

The proposed rules to revise the definition of a "small bank'' to raise the asset size threshold to $1 billion is excessive. While I can understand a need to revise the threshold to reduce the burden on smaller institutions, it is important to ensure that the spirt of the CRA-- to ensure credit and banking services to low- and moderate-income (LTM) consumers-- is not violated.. Based on my experience as a former bank examiner for the OCC, the OTS, and the Federal Reserve, and who conducted several CRA examinations under the latest rules, raising the threshold from $250MM to $1 billion will impact on low- and moderate-income communities in larger MSAs, as it is likely that under the increased thresholds, institutions will feel less pressure to demonstrate how they have served their local communities. Consumers in those LTM groups would likely find reduced access to credit and their banking options would be limited to the larger regional, national banks. This lack of options and decreased competitive bank services would translate to higher banking costs and a limited array of services for an already unbanked group of Americans. Once again, we would find the infamous situation of butique banks that focus their market on wealthier customers serving their CRA obligations through token charity donations and activities.

What LTM consumers need are real and definite options for accessing credit and banking services to fund their home and consumer goods purchase and finance their small business. The access to real and affordable credit is already reduced given the financial woes of local governments. Consequently, the private sector is the primary option for these services. So I urge the regulatory authorities to weigh the need for reducing the administrative burden on banks and examination staff with the needs of an ever-expanding group (given recent census statistics on poverty levels in this country) of Americans.

Sincerely,

Juana Escobedo Teixeira
4079 Brookside Manor Drive
Tucker, GA 30084