FDIC Federal Register Citations
Cameron State
Bank
October 18,
2004
Robert E Feldman, Executive Secretary
Attention: Comments / Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429
Ref: Proposed Amendments to CRA
Dear Mr. Feldmen:
In a proposed amendment to the Community Reinvestment Act in FIL–108–2004
your agency asked banks for their comments. This amendment would change
the definition of a small institution to mean an institution with total
assets of up to $1 billion.
I work for a community bank that has become a “large bank” under
the CRA. Our institution has had to deal with the increased regulatory
data and reporting community development loans. The data that is required
on its small business is very burdensome.
The investment test for a community bank to attain a satisfactory rating
is very difficult. We compete for suitable investments in our market
with billion dollar regional and national banks that have an unfair advantage
due to their size. They literally will spend whatever it takes to get
those investments. The smaller institutions are then at a disadvantage
during exam time.
Our institution is in favor of changing the definition of a small institution
to one with total assets of up to $1 billion without regard to the holding
company assets.
Sincerely,
Connie L Johnson
Asst. Branch Manager
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