From: Pam Zbylut
Sent: Friday, August 27, 2004 4:57 PM
To: Comments
Subject: RIN number 3065-AC50
RE: Proposal to Revise CRA
I want to express
our bank's support for revisions to the Community Reinvestment
Act
that will (a) change the definition of "small
bank" to raise the asset size threshold to $1 billion regardless
of holding company affiliation; (b) add a community development activity
criterion to the streamlined evaluation method for small banks with
assets greater than $250 million and up to $1 billion.
Raising the threshold to $1 billion regardless of holding company
affiliation does reduce regulatory burden for banks.
Evaluating community
development activities as a separate component for banks in the
$250 million
to $1 billion asset category also reduces
regulatory burden. Banks in the $250 million to $1 billion size may
have difficulty receiving a "Satisfactory" on the lending,
investment, and services tests due to limited resources (people/man-hours
and money) as compared to mega banks and banks over $1 billion. Banks
in the $250 million to $1 billion size may already be performing
significant community development activities based on their size
which may result in a Satisfactory rating under the new community
development criterion to be added to the streamlined evaluation.
Thank you for your consideration of these comments.
Sincerely,
Pam Zbylut
Audit/Compliance Manager
Security National Bank of Omaha
Omaha, Nebraska
