Skip Header

Federal Deposit
Insurance Corporation

Each depositor insured to at least $250,000 per insured bank



Home > Regulation & Examinations > Laws & Regulations > FDIC Federal Register Citations




FDIC Federal Register Citations

Bank of the Pacific

Wednesday, February 18, 2004

Federal Deposit Insurance Corporation
Robert Mooney, Assistant Director
550 17th Street, NW
Washington, DC 20429

Dear Mr. Mooney:

In response to your request that all banks give comment on the proposed rulemaking regarding the Community Reinvestment Act, we have several points to offer for your consideration.

The Bank of the Pacific is a community-based bank in rural coastal communities located in Southwestern Washington. The banks mission statement is to be the best to our employees, customers, investors and communities. In the past two years we have been working on the transition from small bank to large bank requirements. Our deposit size continues to increase and we will approach the $500 Million proposed threshold within the next year. In our current business climate and ever growing economy we suggest that the threshold be raised to one billion before being classified as a Large Bank.

The time commitment to meet all regulatory requirements under the large bank designation is an unwarranted burden of time and expense. We will continue to strive for personalized service in our small town atmosphere and within the areas that we do business in spite of the asset size.

Since we have been transitioning to Large Bank requirements we find that the competition for Community Investments and Community Development Loans are much more difficult to obtain. The bank does not have the staff or the resources to compete in that market.

With regard to proposal two in your letter of February 6, 2004, to better address evidence of illegal credit practices and abusive lending practices, this already falls under the Fair Lending Act and other bank compliance regulations and should not be considered here.

The regulation requirements should also extend to the participation of other non-financial institutions such as Credit Unions, Mortgage Companies and issuers of credit cards not affiliated with banks presently reporting CRA activity.

Thank you for your time and consideration.

Laura C. Smith
CRA Officer
Bank of the Pacific
Aberdeen, WA
 

Last Updated 04/13/2004 regs@fdic.gov

Skip Footer back to content