FIRST NATIONAL BANK, JASPER
FIRST STATE BANK OF LIVINGSTON
From: Ben Ogletree [mailto:Ben@fsblivingston.com]
Sent: Thursday, September 16, 2004 3:13 PM
To: Comments
Subject: CRA Proposal
On behalf of our two rural small town banks, First National Bank,
Jasper, Texas, and First State Bank of Livingston, Livingston, Texas, I
would like to comment on the proposal to increase the Community
Reinvestment Act threshold for small banks to $1 billion.
I am strongly in favor of this proposal.
The increase in the threshold would greatly relieve the regulatory
burden on our banks. We have consistently received very good marks in
both banks in the area of community development, but it is painful and
expensive to have to keep the records to verify our CRA activities.
I support the addition of the community devloepment criterion to the
examination for larger community banks, but believe this criterion
should be applied to banks greater than $500 million in assets.
We find the entire methodology of the CRA examination to be modeled
for urban banks with business in various identifiable community areas.
The communities served by our banks tend to be much more homogeneous,
without identifiable pockets of low/moderate income. It is very
difficult to make any meaningful analysis based on geographical
considerations.
I oppose including the Community Development criterion a separate
test of the bank's overall CRA evaluation. I feel it is much more
important to evaluate the banks' overall lending efforts in their
communities.
I support the proposal to change the definition of "community
development" so that it does not focus solely on low to moderate income
persons' needs, but rather, examines how efficiently banks lend into
their rural communities.
Yours truly
Ben R. Ogletree, Jr.
Chief Executive Officer First State Bank of Livingston
First National Bank, Jasper
Members of: East Texas Bancshares Inc. holding company
