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FDIC Federal Register Citations



NEW JERSEY LEAGUE OF COMMUNITY BANKERS

April 2, 2004

Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Re: Community Reinvestment Act Regulations – No. 2004-04
69 FR 5729 (February 6, 2004)

Dear Mr. Feldman:

The New Jersey League of Community Bankers? (“the League”) is pleased to comment on the proposal to revise and update the Community Reinvestment Act (“CRA”) regulations.

The League strongly supports the proposed revisions to the CRA regulations and urges the federal banking regulatory agencies to further reduce the regulatory burden on smaller institutions by amending the definition of “small institution” to mean an institution with total assets of less than $1 billion, without regard to any holding company assets.

The small institution performance standards under the CRA regulations recognize that smaller institutions do not have the resources that larger institutions have to collect the data necessary for the reporting required of larger institutions. Smaller institutions also do not have as many options open to them for meeting the investment test. League members note that large institutions, because of the size of the investments they can make, have more opportunities open to them for investments that qualify for CRA credit.

Raising the threshold for institutions that must comply with the requirements for large institutions would be a major step in reducing the regulatory burden for smaller institutions. Our members are community banks that strongly believe in reinvesting in the communities they serve. Raising the threshold will not dampen that commitment to their communities.
The League also supports the provisions of the proposed regulation that would take evidence of discriminatory or other illegal credit practices into account in an agency’s evaluation of an institution’s CRA performance. The League believes that even one predatory loan is one too many.

Sincerely,

James R. Silkensen, Executive Vice President
New Jersey League of Community Bankers


 

Last Updated 04/26/2004 regs@fdic.gov

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