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LITCHFIELD BANCORP
From: Mark Macomber [mailto:macomber@litchfieldbancorp.com]
Sent: Tuesday, September 28, 2004 4:02 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50
Mark Macomber
President & CEO
Litchfield Bancorp
294 West Street
Litchfield, CT 06759
September 28, 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
community bankers and, representing Americas Community Bankers, I have
testified before a House sub-committee to that effect. 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 my bank is actually doing that which is its only
option - serving all elements of the local community.
My bank is $170 million in assets, so today falls below the existing
threshold. Our sister bank in Connecticut's only mutual holding company,
Northwest Community Bank, is about $270 million in assets and falls
above the threshold. There is virtually no difference in how we conduct
our businesses or in our firm, proactive commitment to the communities
we serve, yet Northwest is burdened, and that is the word, with
excessive and largely meaningless paperwork. The requisite time and
effort could be / would be better spent in productive matters.
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.
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 and thank you for proposing this
much need change.
Sincerely,
Mark Macomber
860-567-9401
President & CEO
Litchfield Bancorp
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