From: Judy Usitalo [mailto:jusitalo@snb-t.com]
Sent: Thursday, September 16, 2004 3:30 PM
To: Comments
Subject: CRA Proposal
The purpose of this email is to strongly support the FDIC’s proposal
to raise the threshold for the streamlined small bank CRA examination to
$1 billion without regard to the size of the bank’s holding company.
Currently, we smaller banks are expected to meet regulatory standards
imposed upon the nation’s largest banks and this is not fair or
rational. Our bank is in a rural area and finding appropriate CRA
qualified investments is difficult. This results in smaller banks having
to make regional or statewide investments that are unlikely to ever
benefit our smaller communities. Certainly this is NOT what Congress had
in mind when CRA was enacted. We also strongly oppose making the CD
criterion a separate test from the bank’s overall CRA evaluation. The
current small bank test considers the institution’s overall lending in
its community. A separate test would create an additional CD obligation
and regulatory burden.
We support the FDIC’s proposal to change the definition of “community
development” from only focusing on low and moderate income area
residents to including rural residents. It is time to turn the tables in
fairness to small, rural community banks and not force them to invest in
regional affordable housing bonds for an urban area and not in the
bank’s own community.
Thank you for your consideration of our request.
Sincerely,
Judith M. Usitalo
Vice President
Superior National Bank & Trust Company
