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Citrus & Chemical Bank
From: Cheryl Nakashige
Sent: Monday, January 09, 2006 2:59 PM
Subject: FDIC RIN #3064-AC97
To Whom it May Concern:
The following are comments related to the CRA Questions and Answers Notice that I would like you to please take into consideration:
Revised Community Development Definition
Proposal: The revised community development definition is applicable to all banks and not just intermediate small banks.
Comments: I agree with the proposed comments that the definition should apply to all banks.
Proposal: The guidance proposes a one-year "lag period" during which a bank may continue to receive consideration for activities in a disaster area for which the designation has expired.
Comments:I believe the one-year "lag period" is not enough time for a bank to finish with community development investments or loans, and would recommend a two-year "lag period" instead. The bank I currently work for, and the preceding one, are located in the Central Florida area. Three major hurricanes had a direct hit in Central Florida in a six-week period in August-September 2004. To date, all the work to recover from those hurricanes has still not been fully completed due to a number of issues such as insurance, not enough contractors, negotiations with governments, etc. I cannot see with the magnitude of Hurricane Katrina in the New Orleans and surrounding areas that a one-year "lag period" is sufficient. Most articles I have read state that it will be several years before things return to normal. An extended period of time is requested.
I agree with all the other proposed Q&As and do not have any further comments for revisions. Thank you for your consideration of this comment.
Cheryl A. Nakashige, VP
|Last Updated 01/09/2006||Regs@fdic.gov|