From: Walter Birdwell [mailto:wbirdwell@citizensbankcarthagetn.com]
Sent: Monday, April 19, 2004 5:31 PM
To: Comments
Subject: EGRPRA Review of Consumer Protection Lending Related Rules
Walter Birdwell
407 Main St.
Carthage, TN 37030
April 19, 2004
Dear FDIC:
Gentlemen:
As a community
banker for fifty years, I know first hand the problems of
meeting the ever increasing regulatory burdens placed on banks today. Our
bank is located in the central part of Tennessee, has $430,000,000. in
assets, operates nine offices, and has 550 stockholders. The so-called
consumer protection regulations are so complicated that consumers cannot
understand the disclosures they are given. From the bank's point of view
one requirement would not be difficult but requirements on top of each
other have become so burdensome relief is needed.
The areas we
find unnecessarily burdensome are:
Disclosures required
becasue we have over 500 stockholders - Even though
this is a Securities and Exchange ruling, the FDIC administers this for
banks. It applies the same requirements to non publicaly traded banks as
those who are publicaly traded.
Right of Rescission
under Regulation Z - This is disruptive to borrowers
who want immediate access to funds from a loan. It would be helpful if
customers could more easily waive the right of rescission.
CRA Requirements
- The investment requirement for banks over $250,000,000
($500,000,000 as proposed) is almost impossible to meet and to understand.
The samll bank threshold should be raised to at least $2 billion to
completely differentiate small and large banks.
Home Mortgage
Disclosure Act (HMDA) - The volume of the data required is
very burdensome. These costs must be passed on to the consumers who
always end up paying for our reporting.
Flood Insurance
- Our bank in in a hill area where flood areas are clearly
defined. We have the responsibility to obtain flood insurance where
needed. However, we must make a detailed disclosure even though the
property is on top of a hill.
Transfers from
MMDA - Restrictions on these transfers should be
liberalized to allow at least one each day.
We feel like
we spend more time reading and trying to understand the
regulations than waiting on customers and providing them with the best
banking services.
Sincerely,
Walter G Birdwell, Jr.
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