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FDIC Federal Register Citations





Franklin Savings Bank

From: Magoon, Ronald [mailto:Magoon@fsbnh.com]
Sent: Thursday, September 16, 2004 9:57 AM
To: Comments
Cc: 'psmith@aba.com'
Subject: RIN No. 3064-AC50

Mr. Robert E. Feldman
Executive Secretary
FDIC

Dear Sir:

I am the Senior Vice President, Treasurer and CFO of Franklin Savings Bank in Franklin, New Hampshire. My bank serves many small communities in Central New Hampshire; with our headquarters located in a small city with under 9,000 residents. Franklin Savings has 6 offices and $273 million in assets.

I am writing to support the FDIC's proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of the bank's holding company. This would greatly relieve the regulatory burden imposed on the small banks under the current regulation. Community banks would still be required to help meet the credit needs of their entire communities and would continue to be so evaluated by their regulator.

As I write this email, our bank is in the middle of a two week long charity softball tournament that we sponsor. This is the eleventh year we have held this softball tournament. Local organizations enter coed teams to compete in this event. Local organizations donate food and drinks to be sold in the concession stand. Local organizations donate giveaways for the raffle. Franklin Savings Bank enters a team in the tournament, sells raffle tickets, organizes all aspects of the tournament from scheduling the umpires to raking the field, and employees man the concession stand. All monies raised from this event go to local charities. This year we are playing for local soup kitchens.

Franklin Savings Bank created a $1 million Fund for Community Advancement in 1997. This Fund provides grant monies to local non-profit organizations to support a wide variety of causes including: families in crisis, community development projects, community mental health, building funds for libraries, improvements to ballparks, specially equipped vans to transport the elderly, and the list goes on.

As you can see from just these two examples - we are what community banking is all about. Unfortunately, we often don't receive "credit" for the countless hours and considerable dollars that we (and our employees) contribute to our communities. However if you were to ask those in our communities about Franklin Savings Bank, I sincerely believe you would hear just how important we are to those who live here.

I strongly support the FDIC's proposal to change the definition of "community development" from only focusing on low and moderate income area residents to including rural residents. This change will go a long way toward eliminating the current distortions in the regulations that result in a small rural bank being told to invest in regional affordable housing bonds for an urban area not in our community.

I do, however, think this change in "community development" criterion should apply to banks much larger than Franklin Savings Bank. I believe the FDIC should adopt its original $500 million threshold for small bank examinations, and apply the community development criterion to banks between $500 and $1 billion in assets as an additional component of the small bank exam.

As a small community bank, we have limited financial resources. As you can see from this correspondence, our preference is to do as much as possible for those living in our communities. The more we spend to comply with the myriad of regulations that we much contend with each and every day, the less time and money can be given back to those truly in need.

I encourage the FDIC to consider my comments thoughtfully so that we may continue to do what we do best - community banking.

I would welcome further questions or comments on this matter.


Respectfully submitted,

Ronald L. Magoon
SVP, Treasurer & CFO
Franklin Savings Bank


Last Updated 09/17/2004 regs@fdic.gov

Last Updated: August 4, 2024