From: H. Barton
Hann
Sent: Monday, February 09, 2004 3:01 PM
To: Comments
Subject: Proposed Amendments to 12CFR Part 345 CRA
Our financial institution strongly supports all proposed amendments
to
12 CFR Part 345, the Community Reinvestment Act Regulations, published
on February 6, 2004. We encourage the Board to adapt all proposals,
without change, at the earliest date after the comment period has
ended.
Our financial institution is subject to becoming a "large" bank,
over
the next year, under the current $250 million threshold. Our
institution has always been strongly committed to meeting the credit
needs of our community, including the low and moderate-income
communities, and our CRA performance ratings echo this commitment.
The
expanded recordkeeping and other related requirements that we will
soon
be subject to, under the "large" bank CRA standards, will
prove to be
burdensome and expensive for an institution our size. With total
assets
of just over $250 million, we certainly do not consider ourselves
a
"
large bank" in any other context other than the outdated CRA
regulations. We strongly request the Board to adapt the proposals
to
raise the large bank asset size to $500 million for CRA purposes.
Thank you for allowing us the opportunity to comment.
H. Barton Hann, VP/Risk Management
Reliance Savings Bank (30117)
Altoona, PA