First
Federal fsb
From: George Loban
Sent: Thursday, September 09, 2004 5:02 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50
George Loban
Co-Chair & President
First Federal fsb
1320 S. Frontage Rd
Hastings, MN 55033
September 9, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Robert Feldman:
As a community banker, I am pleased to comment in support of the
proposal
issued by the FDIC that would amend the definition of a small institution
to be a bank that is under $1 billion in assets. I believe that this
change will provide much needed regulatory burden relief for me and
other
community bankers. It seems that every week there is a new or additional
regulation with which we must comply. This is one example of regulatory
burden relief that will really make a difference. I would much rather
use
the limited resources available to my bank to serve my community
than to
collect and maintain data and documents to prove to examiners that
I am
meeting the needs of my community.
First Federal fsb has $505,192,000 in assets, and we have 230 employees,
181 full-time and 49 part-time. Our community consists of all or
part of
8 counties including both metropolitan and rural areas.
Compliance with the Community Reinvestment Act is something we take
very
seriously at our bank. We don’t just believe it is the right
thing to do;
we believe it is the right business thing to do. No community bank
can
survive and compete without meeting the needs of its customers and
communities. We believe in our community and in our customers and
want to
work with them to provide products and services that best meet their
credit needs. We do not need a complicated examination process to
show
that we are complying with the law.
It is absurd to think that a bank thousands of times larger than
my own
community bank should be examined using the same procedures. I strongly
urge you to amend the definition of a small bank for CRA purposes
to be an
institution with less than $1 billion in assets, regardless of whether
the
bank is part of a holding company. This is a good proposal and is
the
right thing to do.
Thank you for considering my views.
Sincerely,
George B. Loban,
Co-Chairman & President
Co-Chair & President
First Federal fsb
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