Community Bank
From: Cindy Bailey
Sent: Monday, August 30, 2004 5:25 PM
To: Comments
Subject: RIN Number 3064-AC50
August 24, 2004
FDIC
RIN Number 3064-AC50
To whom it may Concern,
As a community bank, we strongly endorse the new proposal
under the
Community Reinvestment Act Regulation. Community Bank supports
the
consideration of a range of other alternatives involving the
small bank
asset threshold and the evaluation of community development
activities.
• Change the definition of “small bank” to
raise the asset size threshold to
1 billion with no consideration of holding company ownership.
• Add a community development activity criterion to the streamlined
evaluation method for small banks with assets greater then
250 million up to
1 billion.
•
Expand the definition of “community development” to
encompass a broader
range of activities in rural areas.
Changing
the asset size for a “small bank’ to
1 billion makes a tremendous
amount of sense. The asset size of 250 million is considered
quite small in
today’s environment of multi-million dollar institutions.
The change would
help keep the focus of small institutions on lending and would
be entirely
consistent with the purpose of CRA. Not to mention the fact
a large
institution test requires qualified investments the small bank
might not be
able to accomplish or not be able to compete in the investment
arena with
multi-billion dollar institutions.
Community development in rural areas should be assessed in
a different light
then the urban areas. Community development activities in rural
areas may
benefit low and moderate individuals as well as the rural community
as a
whole. The activity should warrant consideration even if the
activity is
not located in a low to moderate census tract.
The proposed
criterion would assess an institution’s
record of helping to
meet the credit needs of its assessment area through a combination
of its
community development lending, qualified investments, or community
development services, one or two not all three, would permit
institutions to
better balance the community development activities based on
the
opportunities in the intuitions market area.
In conclusion Community Bank supports the FDIC proposed changes
in the
Community Reinvestment Act as stated above.
Sincerely,
Community Bank
Joseph, OR 97846
Cindy Bailey
AVP/Compliance and CRA Officer
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