Dear Mr. Feldman:
In theory, the proposed regulation to increase the asset size of a small
bank in definition to $1 billion would increase the resources of a newly
defined small bank to serve its community. In practice, however, the
banks would be empowered to use the inherited resources and ease on
accountability to the community in ways they choose. In a contemporary
corporate climate that has time and time again demonstrated that integrity
is suffering great compromises for the sake of increasing profits or
justifying 'competitiveness', I see no motivation or sound logic to
expose communities to the risk that the newly defined small banks neglect
community needs upon inheriting increased resource flexibility.
Furthermore, let's ask why the $250 million bench mark was set at its level
in the first place? Isn't increasing the number to a number 4 times its
original amount a bit drastic and potentially irresponsible to
communities given the percentage increase in 'small' banks that would
result, the total asset amount of those banks now committed to communities,
the current community need being met by that asset amount and a climate
that can not guarantee that that amount will maintain its community focus
in good faith?
I fear that proposal Community Reinvestment 12 CFR Part 345, in practice,
would offend its proposed good intentions with a negative net in meeting
overall community need as a result of its inception.
Thank you for your consideration.
Julian Maynard
United Way of Mass. Bay
245 Summer Street, Suite 1401
Boston, MA 02210
