From: Joan Stephenson (Main)
[mailto:JStephenson@prairiestatebank.com]
sent: Tuesday, March 23, 2004 11:43 AM
To: Comments
Subject: Proposed Revisions to the Community Reinvestment Act
Regulations
I am writing to support the federal bank regulatory agencies'
proposal to enlarge the number of banks and savings associations that
will be examined under the small institution CRA examination. The
Agencies propose to increase the asset threshold to $500 million and to
eliminate any consideration of whether the small institution is owned by
a holding company. This proposal is a major step towards an appropriate
implementation of CRA and will greatly reduce regulatory burden on those
institutions newly made eligible for the small institution examination,
and I strongly support both.
When the small institution examination was introduced in 1995 it
created a simple, understandable assessment test of the bank's record of
providing credit in its community while decreasing, somewhat, the paper
and regulatory burden. Since then, the regulatory burden on small banks
has grown substantially, including massive new reporting requirements
under HMDA, the USA Patriot Act and the privacy provisions of the Gramm-Leach-Bliley
Act. But the nature of community banks has not changed. Prairie State
Bank is, officially, considered a large institution for CRA purposes
beginning January 1, 2004. While our assets may have reached $250
million, the overall structure of our bank has not. The imposition of
the dramatically higher regulatory burden of the large bank CRA
requirements drains both money and personnel away from helping to meet
the credit needs of our communities.
While community banks will still be examined under CRA for their
record of helping to meet the credit needs of their communities, this
change will eliminate some of the most problematic and burdensome
elements of the CRA regulation from community banks that are drowning in
regulatory red-tape.
Sincerely,
Joan Stephenson
Vice President
Prairie State Bank
512 State St.
Augusta Ks 67010
