Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington D.C. 20429
Attn: Docket No. 04-06
Dear Mr. Feldman:
The Minnesota Bankers Association (MBA) is pleased to have the
opportunity to comment on the proposed revisions to the Community
Reinvestment Act. The MBA is a trade group representing nearly 500
Minnesota banks. The MBA membership includes a broad range of banks,
from independent community banks to regional banking organizations
operating in multiple states.
The MBA strongly supports the Federal banking agencies’ proposal to
increase the asset size of banks eligible for the small bank CRA
examination and to eliminate the holding company size requirement.
Banks’ regulatory burden has increased greatly over the past few years
with the passage of such laws as the Gramm-Leach-Bliley Act, the USA
PATRIOT Act, and the FACT Act. Most of the MBA’s member banks are not
large enough to afford a full-time compliance officer and while they
understand the need for the myriad of banking regulations, they find
complying with them extremely burdensome. Changing the asset threshold
to $500 million will decrease the regulatory burden for many of our
member banks, leaving more time for bank employees to meet the credit
needs of their community.
Eliminating the holding company size requirement will also reduce the
regulatory burden for many of our member banks. As noted in the Proposed
Rules, small banks with sizable holding companies find complying with
CRA requirements just as difficult as small banks without sizable
holding companies. When examined under the large bank requirements based
on their holding company status, small banks that are part of sizable
holding companies are at a competitive disadvantage. Such banks should
be measured with their peers, not put on the same playing field as large
banks.
We thank you very much for considering our input on this proposed
revision. If you have any questions concerning this comment letter, do
not hesitate to call me at (952) 835-3900.
Sincerely,
Tess Rice
General Counsel
Minnesota Bankers Association
