Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
RE: 12 CFR Part 345
Dear Mr. Feldman:
As the Compliance Officer for Bank of North Carolina based out of
Thomasville, North Carolina, I appreciate the opportunity to comment
with respect to the proposed amendments to the CRA regulations.
Increasing the asset threshold for what constitutes a "small
institution" for CRA purposes to $500 million, or preferably $1 billion,
would clearly be a positive step toward reducing regulatory burden
without diminishing the purpose for which the Community Reinvestment Act
was enacted in 1977. Since the CRA regulations were revised in 1995,
small banks have become subject to significant new regulatory
requirements while continuing to provide quality financial services to
the communities we serve. Increasing the asset threshold for small
institutions to $500 million would reduce the amount of total industry
assets subject to the CRA test for large institutions by less than one
percent. Raising the threshold to $1 billion would result in a reduction
of only four percent. To increase the asset threshold to the higher
amount would effectively address current circumstances as well as
anticipated industry growth.
I appreciate the opportunity to comment regarding this important
issue and urge the Agencies to adopt the recommended CRA amendments.
Michelle W. Ferguson
Assistant Vice President
Compliance Officer
Bank of North Carolina
831 Julian Ave
Thomasville, NC