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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

FIRST CITIZENS NATIONAL BANK

September 17, 2004

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

Dear Mr. Feldman:

As a community banker for more than four decades, I have witnessed many changes in the regulatory environment. Many of the' rules, laws and regulations which govern our industry are certainly warranted and work in the best interest of the industry as a whole as well as the customer base we serve. On occasion they do not. With this thought in mind, I join my fellow community 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. The proposal will greatly alleviate unnecessary paperwork and examination burden without weakening our commitment to reinvest in our communities. Reinvesting in our communities is something we do everyday as a matter of good business.

It is important to remember that the streamlined CRA exam is not an exemption from CRA. Banks subject to the simplified CRA exam are still fully obligated to comply with CRA. Many community banks (especially those in rural areas) have to invest in regional or statewide mortgage bonds or housing bonds and the like to meet CRA requirements. These investments may benefit other areas of the state or region but they actually take resources away from the bank's local community. 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 advantage to this proposal is that it continues to focus on community development; but considers investments, lending and services.

By easing 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 considering my views.

Sincerely,
Katie Winchester
President, CEO & Vice Chairman
First Citizens National Bank, Dyersburg, TN
 

Last Updated 10/16/2004 regs@fdic.gov

Last Updated: August 4, 2024