NORTHSIDE COMMUNITY BANKFrom: Jim Randall [mailto:Jim.Randall@nscombank.com]
Sent: Tuesday, September 14, 2004 3:46 PM
To: Comments
Cc: Psmith@aba.com
Subject: RIN No. 3064-AC50
Mr. Robert E. Feldman
Executive Secretary-Attention Comments Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
RE:RIN Number 3064-AC50
Dear Sir:
I am Chairman of NorthSide Community Bank in Gurnee Illinois, which
is a suburb of Chicago, with approximately 23,000 residents. It has over
23 banks and many credit unions and is surrounded by similar sized
suburbs with as many banks per town. NorthSide Community Bank is a de
novo bank that in seven years has grown to over $463 million dollars in
Assets. We have done well by lending in our community and region, and
have a loan to deposit ratio in excess of 110%. We firmly believe that
based on our years in the banking industry that the current numeric CRA
tests have strayed beyond any initial intent of congress, and are
counterproductive and duplicative, as well as being hopelessly outdated
by internet banking, telephone banking, the ATM systems ETC..
I am writing to STRONGLY support the FDIC's proposal to raise the
threshold for the streamlined small bank CRA examination to a minimum of
$1 Billion OR MORE. This would help us focus on what we do best, loan
money, not provide meaningless paper trails to audit. We estimate the
cost needed to comply at over $100,000 per year at least, and we are
actually stalling our growth to some degree to stay under the
$500,000,000 asset size as long as we can. This is not a heathy attitude
for job creation and expansion, but the reality is we do not wish to be
subject to different increased levels of governmental reporting.
I strongly oppose making a separate test for Community Development
loan criterion. This is just an expansion of the CRA overall evaluation
which would confuse the animals in the zoo and require more training,
more cost, more wasted effort.
I believe that the FDIC has proposed a major improvement in the CRA
regulations, and I urge the FDIC to adopt its proposal.
Sincerely,
James S. Randall
Chairman
NorthSide Community Bank
5103 Washington Street
Gurnee, Illinois, 60031
Phone 847-244-5100
