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FIRST STATE BANK
From: Jess Laird [mailto:JLaird@FSBAthens.com]
Sent: Thursday, September 16, 2004 12:22 PM
To: Comments
Subject: RIN number 3064-AC50
I am writing in support of the FDIC’s proposal to raise the threshold
for streamlined small bank CRA examination to $1billion. Since our
bank’s asset size is approximately $250MM which is the current limit for
streamlined CRA examination, we are very aware of the significance of
this proposal. I strongly believe passing this proposal would decrease
regulatory burden without impacting our bank’s desire and ability to
meet the credit needs of our entire community.
I also believe the additional community development criterion should
be applied (at most) to community banks between $500MM and $1billion. In
year’s past as our bank has approached “large bank” status for CRA
purposes I have searched for suitable CRA qualified investments in our
community and found them to be unsuitable or non-existent. We are a
community bank and I do not believe the intent of Congress was that we
go well outside our community and market area for investments which do
not help meet the needs of “our” community.
Therefore, I oppose the creation of a separate community development
evaluation. This evaluation is not necessary since lending is already
examined in the streamlined exam. An additional CD lending evaluation
would create unnecessary regulatory burden from which we are asking
relief.
I also strongly 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.
Thank you for the opportunity to write in support of this FDIC
proposal.
Jess Laird, President
First State Bank
Athens, Texas
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