Baltimore
County Savings Bank
From: Gary C. Loraditch [mailto:gloraditch@bcsb.net]
Sent: Wednesday, September 29, 2004 12:44 PM
To: Comments
Subject: SPAM::Community Reinvestment: RIN number 3064-AC50
Gary C. Loraditch
President
Baltimore County Savings Bank
PO Box 397
Perry Hall, MD 21128
September 29, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Robert 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. I believe that this
change will provide much needed regulatory burden relief for me and
other
community bankers. It seems that every week there is a new or additional
regulation with which we must comply. This is one example of regulatory
burden relief that will really make a difference. I would much rather
use
the limited resources available to my bank to serve my community
than to
collect and maintain data and documents to prove to examiners that
I am
meeting the needs of my community.
Baltimore County Savings Bank is a $750,000,000 community financial
institution serving the Baltimore Metropolitan area with 16 offices
and
192 employees. Its holding company, BCSB Bankcorp, Inc. is a mutual
holding company traded on the NSADAQ under the symbol "BCSB".
Compliance with the Community Reinvestment Act is something we take
very
seriously at our bank. We don’t just believe it is the right
thing to do;
we believe it is the right business thing to do. No community bank
can
survive and compete without meeting the needs of its customers and
communities. We believe in our community and in our customers and
want to
work with them to provide products and services that best meet their
credit needs. We do not need a complicated examination process to
show
that we are complying with the law.
It is absurd to think that a bank thousands of times larger than
my own
community bank should be examined using the same procedures. I strongly
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 is a good proposal and is
the
right thing to do.
Thank you for considering my views.
Sincerely,
Gary C. Loraditch
410-256-5000
President
Baltimore County Savings Bank
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