From: Peter Clements
[mailto:peter.clements@bsvnet.com]
Sent: Friday, March 19, 2004 5:56 PM
To: Comments
Subject: Proposal to raise small bank CRA evaluation to 500 million
Ladies and Gentlemen,
As one of the Banks who has been advocating this position ever since
we crossed the 250 million dollar size threshold I would like to support
the proposal that is being considered by the FFIEC. Our bank has been
rated "outstanding' both under the old guidelines and the new ones
although it took one full cycle to be able to meet the higher
documentation requirements once we surpassed the "large bank" limit. It
was not an easy task and was accomplished only with the assistance of
the CRA Examination team that helped us through the maze of information
required.
Being a Community Banker headquartered in a town of about 300 I find
it incredible that we operate under the same rules as Citigroup or The
Bank of America. I realize that the proposal will probably not apply to
my institution very much longer as we are nearing 450 million in Assets
but I do think it is long overdue. The vast majority of banking assets
will still be covered but the small institutions without the large staff
to document CRA activities will have some relief. My suggestion would be
to make the threshold 1 billion dollars and index it to inflation so
that this debate will not have to take place any more than once. Thank
you for your proposal and consideration. It is much appreciated and
needed.
Sincerely,
Peter Clements
President & CEO
The Bank of Southside Virginia