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FDIC Federal Register Citations
Community Bank & Trust
From: Marilyn Wilde [mailto:mwilde@cbtwaco.com]
Sent: Wednesday, October 13, 2004 4:27 PM
To: Comments
Subject: FW: CRA Proposal Letter
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50: FDIC Proposed Increase in the Threshold for the
Small Bank CRA Streamlined Examination
Dear Sir:
I am Assistant Vice President of Community Bank & Trust, located in
Waco, Texas, a central Texas community of over 100,000 residents. My bank
is $270,000,000 in assets and is already subject to large bank CRA exam.
I am writing to strongly 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 many small banks such as my own under the
current regulation, which are required to meet the standards imposed on
the nation's largest $1 trillion banks. I understand that this is not an
exemption from CRA and that my bank would still have to help meet the credit
needs of its entire community and be evaluated by my regulator.
I strongly oppose making the Community Development criterion a separate
test from the bank's overall CRA evaluation. For a community bank, CD lending
is not significantly different from the provision of credit to the entire
community. The current small bank test considers the institution's overall
lending in its community. The addition of a category of CD lending (and
services to aid lending and investments as a substitute for lending) fits
well within the concept of serving the whole community. A separate test
would create an additional CD obligation and regulatory burden that would
erode the benefit of the streamlined exam.
In conclusion, I believe that the FDIC has proposed a major improvement in
the CRA regulations, one that much more closely aligns the regulations with
the Community Reinvestment Act itself, and I urge the FDIC to adopt its proposal,
with the recommendations above. Thank you for your consideration of my opinion.
Sincerely,
Marilyn A Wilde
Assistant Vice President
Community Bank & Trust
Waco, Texas
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