Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
500 17th Street NW
Washington, DC 20429
RE: Community Reinvestment Act Proposal
RIN 3064-AC50
Dear Mr. Feldman:
I appreciate the opportunity to comment on your proposal to increase
the asset size threshold for small banks under the Community
Reinvestment Act (CRA) from $250 million to $1 billion.
I applaud the FDIC for taking a leadership role among the agencies
and recognizing the regulatory burdens being placed on community banks.
With the passage of Check 21, USA PATRIOT Act, FACTA and changes to HMDA
our already limited resources are stretched thin. Passage of this
proposal would free up the costs of the CRA software, software upgrades
and manpower needed for the data collection process alone, allowing us
to apply some of these resources to the true intent of the CRA –
providing low cost loans and services to members of our community.
With that being said, I do not support additional community
development criterion be set for institutions between $250 million and
$1 billion in assets. Those “freed up” resources I spoke of would need
to be forced back into training and efforts necessary to comply with
those new requirements. The new requirements would not serve the purpose
of this proposal, which is to reduce regulatory burden. Instead, it
would just create additional inconsistencies among the regulatory
agencies.
We understand and support the spirit and intent of the CRA and pledge
to continue our vital role in the development of our community. Our bank
will not survive without a growing, thriving community. The CRA is by no
means being repealed and therefore, we recognize our responsibilities
remain.
Thank you for your consideration.
Gene R. Neighbor
