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September 13, 2004
From: John Rohrback [mailto:jrohrback@freedombankva.com]
Sent: Tuesday, September 14, 2004 4:37 PM
To: Comments
Subject: Streamlined CRA Exam; RIN number 3064-AC50
John Rohrback
502 Maple Ave West
Vienna, VA 22180-4239
September 14, 2004
Comments to FDIC
Dear Comments to FDIC:
As a community banker, I join my fellow community bankers throughout
the nation in strong support of the FDIC's proposal to increase the
asset size limit of banks eligible for the streamlined small-bank CRA
examination. I also strongly support the elimination of the separate
holding company qualification.
The proposal will greatly alleviate unnecessary paperwork and
examination burden without weakening our commitment to reinvest in our
communities. Reinvesting in our communities is something we do everyday
as a matter of good business. My community bank will not long survive if
my local community doesn't thrive, and that means my bank must be
responsive to community needs and promote and support community and
economic development.
Making it less burdensome to undergo a CRA exam by expanding
eligibility for the streamlined exam will not change the way my bank
does business. In fact, it will free up human and financial resources
that can be redirected to the community and used to make loans and
provide other services.
Similarly, the proposal will help rural banks meet the special needs
of their communities by expanding the definition of "community
development" so that it includes activities that benefit rural residents
in addition to low- and moderate-income individuals. Rural banks are
frequently called upon to support needed economic or infrastructure
development such as school construction, revitalizing Main Street, or
loans that help create needed or better-paying jobs. These activities
should not be ineligible for CRA credit because they do not benefit only
low- or moderate-income individuals.
The FDIC's proposed changes to CRA are needed to help alleviate
regulatory burden. Without changes such as this, more and more community
banks like mine will find they cannot sustain independent existence
because of the crushing regulatory burden. By easing regulatory burden,
it will make it easier for community banks like mine to continue to
provide committed service to local communities that few other financial
service providers are willing to do.
Thank you for considering my views.
Sincerely,
John Rohrback
703-242-5300
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