FDIC Federal Register Citations

September 14, 2004

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

Re: Community Reinvestment, RIN No. 3064-AC50

Dear Mr. Feldman:

I am writing to support the FDIC's proposal to increase the asset size limit for banks eligible for the streamlined small-bank CRA exams. The proposed changes make sense for several reasons.

First, the intent of CRA is being well served by banks under $250 million in size; and this certainly won't change as our community banks grow past $250 million. The local loans and investments will continue because they are the life blood of our community banks, and the present small bank CRA exam process ensures that the needs of low and moderate income families are being served. To say that the proposed changes jeopardize the intent of CRA in community banks is flat wrong.

Second, the changes recognize that the size of banks has increased over the years, so the limit for small bank exams should also increase. It is unreasonable to measure a community bank with the same program as a $100 billion bank.

Third, the changes let more small community banks continue to comply with CRA using the less costly small bank approach. The expenses of the big bank requirements are significant, and it is unreasonable to apply them to a community bank simply because it reaches $250 million in assets. These compliance dollars could much better be spent on serving the community instead of documenting a more complicated compliance effort.

I hope you will not yield to the misdirected efforts to stop the proposed changes since the changes would actually help community banks to have more resources to serve all areas of our communities as we grow in size. And, the CRA effort would not be lessened nor would any bank be exempted from CRA.

Thank you for your consideration.

Sincerely,

BANK OF LITTLE ROCK

George G. Worthen
President