I
appreciate the opportunity to comment on the FDIC’s proposed
changes to the CRA definition with respect to the definitions of
small and large
banks. First State Bank
($ 238 million in assets) is a community bank serving its communities
in north central Texas for 99 years. As a community banker, I greatly
welcome the regulators’ effort on raising the threshold.
While regulatory
burden weighs on financial institutions of all sizes, it seems
to fall
heaviest on community banks. I feel the FDIC’s
proposal to reduce this burden for community banks is long overdue.
It is unreasonable to think that a bank my size should be examined
using the same procedures as for $ billion - $ trillion banks.
Although my bank
does not have to track and report loans under the current rules,
I feel
data is available at the time of an exam to
provide examiners with the information on a limited segment of our
portfolio, to demonstrate our lending activities. Also, I feel most
community banks our size can “reinvest” in the communities
we serve – by our devotion of time, energy and financial resources.
Although not required, and with no added benefit to our “small” bank
tests; we currently have loans to Habitat for Humanity and to our
city’s economic development corporation. Without saying, compliance
with the CRA is something we take very seriously. We strive to meet
the credit needs of our customers and communities.
Let us continue
on this path, without the added excessive costs associated with
the “large” bank reporting requirements – costs
that generally are passed on to consumers.
I urge the FDIC Board to approve the proposed increase to $1 billion
in the size of the financial institution eligible for the small bank
CRA examination.
Thank you for your consideration.
Lisa Bezner
Compliance/BSA/CRA Officer
|
