Subject: Comments on proposed amendments to Reg BB - Community
Reinvestment Act
I have been a community banker for almost 29 years. Over those 29
years I have seen the compliance burden grow to a point now that it has
become a burden on the consumer, whose rights were suppose to be
protected by these new regulations. When I first began to make mortgage
loans we could close the loan with less than eight documents. Now before
the customer even sees the final closing documents they are inundated
with at least that many “early disclosures” most of which is of no
concern to them.
This year is the first year we were subject to the “large bank” CRA.
Now we are expected to adhere to the same reporting requirements as a
$10 billion bank. From a CRA standpoint we have always received a one
rating or satisfactory rating. We offer programs that cover every
consumer income range including two programs that offer 100% financing
for the purchase of a new home. We offer numerous “small business” loans
to individuals, corporations and partnerships.
We have enough regulatory burden now and could use some relief and by
increasing the large bank threshold to $500 million would be a step in
the right direction. We realize what CRA is meant to accomplish and I
feel we do a great job meeting the credit needs of the community.
