Western
Commerce Bank
September 20, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: Community Reinvestment, RIN number 3064-AC50; Proposal to Expand
Eligibility for the Streamlined CRA Exam
Dear Mr. Feldman:
I support the
FDIC’s
proposal to make changes to CRA evaluations that would increase
the small institutions threshold from $250 million
to $500 million. Our banks had received outstanding CRA ratings since
this law was passed until Western Commerce Bank, Carlsbad, New Mexico,
exceeded $250 million in assets.
In communities our size it is almost impossible to find a qualified
community investment. We purchased a CRA qualified mutual fund that
will never benefit Eddy County in order to comply with the big bank
rules.
Our bank operates the same now as we did at $100 million in assets.
Our loan to deposit ration is 75% and over the years we have been
the leader in small business loans, affordable housing, small farm
lending, etc.
At our last CRA
exam, the FDIC folks felt sorry for us because they know how important
this rating is to our people. We hadn’t
changed; the business plan hadn’t changed; we just grew a little
too much.
I have been a
New Mexico state Senator for the past 12 years and understand all
too well
about pressure groups. I also understand
the bank’s responsibility to our communities. Years ago, I
was the Federal Reserve’s tame CRA advocate. When I spoke at
meetings, I would encourage bankers to view CRA as a marketing plan.
Everyone in our communities needs the same thing: affordable housing,
transportation, etc. Just the cost is different.
I believe lending is the most important investment we make. Who,
where, how much is not hard to tell and prove we are doing our
job. I believe the same rules should be applied to all community
banks. I understand the examiners need objective goals to refer
to and I believe the under $250 million exam rules to that. By
easing the regulatory burden, it will make it easier for community
banks like Western Commerce to continue to provide community service
to local communities that few other financial service providers
are willing to do.
I still believe CRA is a good and necessary law as long as we can
use some common sense.
Sincerely,
Don Kidd
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