March 15, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Mr. Feldman:
As a community banker, I strongly endorse the federal bank
regulators' proposal to increase the asset size of banks eligible for
the small streamlined Community Reinvestment Act (CRA) examination from
$250 million to $500 million and elimination of the holding company size
limit (currently $1 billion). This proposal will greatly reduce
regulator burden. I am the President/CEO of Citizens Bank and Trust
Company, a $250 million bank located in Van Buren, Arkansas.
The small bank CRA examination process was an excellent innovation.
As a community banker, I applaud the agencies for recognizing that it is
time to expand this critical burden reduction benefit to larger
community banks. At this critical time for the economy, this will allow
more community banks to focus on what they do best--fueling America's
local economies. When a bank must comply with the requirements of the
large bank CRA evaluation process, the costs and burdens increase
dramatically and the resources devoted to CRA compliance are resources
not available for meeting the credit demands of the community.
Increasing the size of banks eligible for the small-bank streamlined
CRA examination does not relieve banks from CRA responsibilities. Since
our survival is closely intertwined with the success and viability of
Van Buren, the increase will merely eliminate some of the most
burdensome requirements.
In summary, I believe that increasing the asset size of banks
eligible for the small bank streamlined CRA examination process is an
important first step to reducing regulatory burden. I also support
eliminating the separate holding company qualification for the
streamlined examination, since it places small community banks that are
part of a larger holding company at a disadvantage to their peers.
Thank you for considering my position on this very important matter.
Sincerely,
D. Keith Hefner
President/CEO
Citizens Bank & Trust Company
Van Buren, AR
