Farmers and Merchants Trust Company of
Chambersburg
September 28, 2004
Mr. Robert Feldman
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, D.C. 20129
Dear Mr. Feldman:
As a community banker, I am pleased to comment in support of the
proposal issued by the FDIC that would amend the definition of a
small institution to be a bank that is under $1 billion in assets.
Each week it appears as if there are new regulations to implement
and an enormous amount of time is spent on the area of the Community
Reinvestment Act (CRA). With limited resources, the regulatory burden
is fast becoming a financial burden to all community banks.
Farmers and Merchants Trust Company of Chambersburg is a community
bank located in rural central Pennsylvania with approximately 195
full time employees. Our bank has assets of approximately $580 million,
which classifies us as a large bank under current CRA standards.
Compliance with
the CRA is a part of every employee’s responsibility,
from tellers to the president and directors. We believe being involved
in and supporting the communities in which we work and live help
to make the communities an attractive resource for new businesses
to locate and existing businesses to expand. We realize that a community
bank cannot survive and compete without meeting the needs of our
communities. It is unfair to think that our bank has to be examined
by the same guidelines of banks that dwarf us in size and resources.
I urge you to amend the definition of a small bank for CRA purposes
to be an institution with less than $1 billion in assets, regardless
of whether the bank is part of a holding company. This would enable
community banks to allocate more resources to our communities to
ensure the progress of our communities and our existence as community
banks.
Sincerely,
John W. Olander
CRA Officer
Assistant Compliance Officer
Consumer Loan Review Officer
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