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FDIC Federal Register Citations



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FDIC Federal Register Citations

CATTARAUGUS COUNTY BANK

September 17, 2004

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

Re: Community Reinvestment, RIN number 3064-AC50; Streamlined CRA Exam

Dear Mr. Feldman,

As a community banker, I join bankers throughout the nation in strong support of the FDIC's proposal to increase the asset size limit of banks eligible for the streamlined small-bank CRA examination. I also strongly support the elimination of the separate holding company qualification.

Reinvesting in our communities is something our bank has done everyday as a matter of good business since 1902. My bank must be responsive the community needs and promote and support community and economic services. I believe that this proposal will greatly alleviate unnecessary burden and paperwork. Making the CRA exam process less burdensome and more streamlined will allow resources to be redirected to the community and used to make loans and provide other services.

It is important to remember that the streamlined CRA exam is not an exemption for CRA. It is a more cost effective and efficient CRA exam. Banks subject to the simplified CRA exam are still fully obligated to comply with CRA. It doesn't make sense nor is it equitable to evaluate a $500 million or $1 billion bank using the same exam procedures as for a $100 billion or $500 billion bank.

Many community banks, especially those in rural areas like my bank, are forced to invest in regional or statewide mortgage bonds or housing bonds and the like to meet CRA requirements. Community banks and Main Street America would be better off if the banks could truly reinvest those dollars locally to support their own local economies and residents.

For this reason, I find that the FDIC's proposed community development requirement for banks between $250 million and $1 billion is more flexible and more appropriate than the large bank investment test. The proposal would allow for keeping the bank's strategies focused and meeting the local community's needs.

The FDIC's proposed changes to CRA are needed to help alleviate regulatory burden. By easing the regulatory burden, it will make it easier for community banks like mine to continue to provide committed service to local communities that few other financial service providers are willing to do.

Thank you for your consideration and anticipated support.

Sincerely,
Salvatore Marranca
President & CEO
Cattaraugus County Bank
Franklinville, NY

Last Updated 10/18/2004 regs@fdic.gov

Last Updated: August 4, 2024