|
UNITEDKINGFIELD
BANK September 17, 2004
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 or Madam:
I am Joanne Campbell, Senior Vice President, of UnitedKinfield
Bank, located in Bangor, Maine. UnitedKingfield bank has
eighteen branches statewide, only two of which are in SMSA's, the
remainder are located in small communities with populations under
5,000. My bank's asset size in $429 million and we recently were
reviewed as a large bank for an FDIC CRA exam due to the size of our
holding company. 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. However, I believe
that this would lower my current regulatory burden by an estimated 40
hours and $5,000.
I also support
the addition of a community development criterion to the small
bank examination
for larger community banks. It appears
to be a significant improvement over the investment test. However,
I urge the FDIC to adopt its original $500 million threshold for
small banks without a CD criterion and only apply the new CD criterion
to community banks greater than $500 million up to $1 billion. Banks
under $500 million now hold about the same percent of overall industry
assets as community banks under $250 million did a decade ago when
the revised CRA regulations were adopted, so this adjustment in the
CRA threshold is appropriate. As FDIC examiners know, it has proven
extremely difficult for small banks, especially those in rural areas,
to find appropriate CRA qualified investments in their communities.
Many small banks have had to make regional or statewide investments
that are extremely unlikely to ever benefit the banks’ own
communities. That was certainly not intent of Congress when it enacted
CRA.
An additional reason to support the FDIC’s CD criterion is
that it significantly reduces the current regulation’s “cliff
effect.” Today, when a small bank goes over $250 million, it
must completely reorganize its CRA program and begin a massive new
reporting, monitoring and investment program. If the FDIC adopts
its proposal, a state nonmember
bank would move from the small bank examination to an expanded but
still streamlined small bank examination, with the flexibility to
mix Community Development loans, services and investments to meet
the new CD criterion. This would be far more appropriate to the size
of the bank, and far better than subjecting the community bank to
the same large bank examination that applies to $1 trillion banks.
This more graduated transition to the large bank examination is a
significant improvement over the current regulation.
I strongly oppose making the CD 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. With
the recent census changes many of our small rural communities are not
considered low or moderate income. Additionally, the entities that
meet these CD definitions are usually situated in service center areas
and not in the smaller communities so to do actual lending that meets
the CD level of definition; in these communities is very difficult. We
do feel that the small business, small farm and residential lending
that we do in these rural communities are meeting the community needs
and should be viewed in whole and actually count towards meeting the
credit needs of the entire community.
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. I will be happy
to discuss these issues further with you, if that would be helpful.
Sincerely,
Joanne T. Campbell
Sr. Vice President
UnitedKingfield Bank
145 Exchange Street
Bangor, ME
|
