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FDIC Federal Register Citations

NORTHSIDE COMMUNITY BANK

From: Jim Randall [mailto:Jim.Randall@nscombank.com]
Sent: Tuesday, September 14, 2004 3:46 PM
To: Comments
Cc: Psmith@aba.com
Subject: RIN No. 3064-AC50

Mr. Robert E. Feldman
Executive Secretary-Attention Comments Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
RE:RIN Number 3064-AC50

Dear Sir:

I am Chairman of NorthSide Community Bank in Gurnee Illinois, which is a suburb of Chicago, with approximately 23,000 residents. It has over 23 banks and many credit unions and is surrounded by similar sized suburbs with as many banks per town. NorthSide Community Bank is a de novo bank that in seven years has grown to over $463 million dollars in Assets. We have done well by lending in our community and region, and have a loan to deposit ratio in excess of 110%. We firmly believe that based on our years in the banking industry that the current numeric CRA tests have strayed beyond any initial intent of congress, and are counterproductive and duplicative, as well as being hopelessly outdated by internet banking, telephone banking, the ATM systems ETC..
I am writing to STRONGLY support the FDIC's proposal to raise the threshold for the streamlined small bank CRA examination to a minimum of $1 Billion OR MORE. This would help us focus on what we do best, loan money, not provide meaningless paper trails to audit. We estimate the cost needed to comply at over $100,000 per year at least, and we are actually stalling our growth to some degree to stay under the $500,000,000 asset size as long as we can. This is not a heathy attitude for job creation and expansion, but the reality is we do not wish to be subject to different increased levels of governmental reporting.

I strongly oppose making a separate test for Community Development loan criterion. This is just an expansion of the CRA overall evaluation which would confuse the animals in the zoo and require more training, more cost, more wasted effort.

I believe that the FDIC has proposed a major improvement in the CRA regulations, and I urge the FDIC to adopt its proposal.

Sincerely,

James S. Randall
Chairman
NorthSide Community Bank
5103 Washington Street
Gurnee, Illinois, 60031
Phone 847-244-5100

Last Updated 09/25/2004 regs@fdic.gov

Last Updated: August 4, 2024