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FDIC Federal Register Citations

TAYLOR BANK

August 26, 2004

Mr. Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

E-Mail: comments@fdic.gov

RE: Notice of Proposed Rulemaking on CRA RIN No.: 3064-XXXX.

Dear Mr. Feldman:

We strongly endorse the Federal Deposit Insurance Corporation's proposal to increase the asset size of banks eligible for the small bank CRA examination to $1 billion. Our bank's regulatory burden has increased greatly over the past few years with the passage of such laws as Gramm-Leach-Bliley Act, the USA PATRIOT Act, and the FACT Act, while we understand the need for the myriad of banking regulations, we find complying with them extremely burdensome. Changing the asset threshold to $1 billion will relieve us of an unnecessary regulatory burden, leaving more time for our employees to meet the credit needs of our community.

Our current asset size is $416 million. We would like to emphasize that banks our size are already at a competitive disadvantage to credit unions and other financial entities that do not have the same regulatory burden as community banks, especially in areas like Community Reinvestment, incurring significant costs in CRA compliance that mane of our competitors (e.g., credit unions) are not.

Also, as an institution that has recently become a "Large Bank" under the definitions of Part 345, we have found that banks should be evaluated against their peers, not banks hundreds of times their size. Large banks with assets in the hundreds of billions of dollars blanket the country. It is not fair to rate a community bank using the same CRA examination.

Additionally, we are pleased that the FDIC has proposed a broad definition of community development to include all activities that benefit not just low- and moderate-income residents but also residents of rural areas.

In summary, we believe it is very important for the FDIC to do all that it can to minimize the burdens associated with CRA. We appreciate the opportunity to comment on this important proposal.

Sincerely,

Reese Cropper, Jr.,
Chairman & CEO
Calvin B. Taylor Banking Co.
24 N Main
Berlin, MD 21811

Last Updated 09/09/2004 regs@fdic.gov

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