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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations


NEW HAMPSHIRE BANKERS ASSOCIATION

September 17, 2004

Mr. Robert Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Re: RIN Number 3064-AC50

To Whom It May Concern:

The New Hampshire Bankers Association (NHBA) is a not-for-profit trade association representing the 39 state- and nationally-chartered banks in New Hampshire. Our member banks range in size from extremely large, multi-state holding companies to small yet well-seasoned mutual savings banks and de novo institutions. Despite the broad spectrum of banks we represent, our Association is strongly united in its support of the FDIC’s proposed increase in the threshold for the Small Bank CRA Streamlined Examination.

It is common knowledge nationwide that the de facto definition of a “small bank” is now $1 billion in assets or less. It is also common knowledge that community banks across the country are being crushed by the huge regulatory burden that has been placed on the banking industry in general. Raising the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of the bank’s holding company would greatly reduce this regulatory burden.

We also support the addition of a Community Development criterion to the small bank CRA test, but only if it is applied to banks between $500 million to $1 billion. Adding the new CD criterion to banks below $500 million in assets would increase the regulatory burden of extremely small institutions and be counterproductive. We also believe that a new CD criterion should be part of the test to evaluate an institution’s overall performance in meeting the needs of its community and not a stand-alone test.

Finally, the NHBA strongly supports the FDIC’s proposal to change the definition of “community development” to include rural residents as well as people who live in low- and moderate-income areas. Two-thirds of New Hampshire lies in a rural region. Modifying this definition would truly allow many small institutions to accurately reflect their efforts to lend into the market areas where they collect deposits. After all, that’s what CRA is all about.

Sincerely,

Gerald H. Little
President

 

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

Last Updated: August 4, 2024