CAMERON STATE BANK
March 15, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429
Re: Proposed Amendments to CRA
Dear Mr. Feldmen:
In FIL-15-2004, your agency asked banks to comment on the proposed
amendments to the Community Reinvestment Act. One of the proposed
amendments would change the definition of a small institution to mean an
institution with total assets of less than $500 million.
I serve as the Compliance Officer for a community bank that became a
"large bank" under the CRA two years ago. Our institution has had to
deal with the increased regulatory burden of data collection and
reporting on its small business, small farm and community development
loans for the last two years. This is very burdensome to community banks
who make the majority of their loans inside their assessment areas.
Another issue involves the CRA examination process. Under the large
bank CRA examination process, the investment test is difficult for a
community bank to attain a satisfactory rating. We compete for suitable
investments in our market with billion dollar regional and national
banks that have an unfair advantage due to their size. They literally
will spend whatever it takes to get those investments. The smaller
institutions are then at a disadvantage during exam time.
Our institution is in favor of changing the definition of a small
institution to one with total assets of $500 million or less without
regard to the holding company assets.
Thank you for considering this matter.
Sincerely,
Tom Baldassari
Vice President
Cameron State Bank
Lake Charles, LA
