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FDIC Federal Register Citations State Bank of Cross Plains From: Charlie Saeman [mailto:charlie.saeman@crossplainsbank.com] September 20, 2004 Robert E. Feldman, Executive Secretary Re: Commuinity Reinvestment, RIN number 3064-AC50 Proposal to Expand Eligibility for the Streamlined CRA Exam Dear Mr. Feldman: I was most pleased with the FDIC’s proposal to increase the asset size limit of banks eligible for the streamlined small bank CRA examination. I encourage and support the FDIC’s efforts to maintain the proposed improvements. Recently our bank was examined for the first time under the larger bank scope of CRA. The additional requirements of the large bank examination which we were subjected to did nothing to change the manner in which we support the needs of our community and only created addition al burdens for our bank. Investing and reinvesting in our communities is something we have done and we will continue to do everyday. A more cost effective examination that simplifies yet verifies our community reinvestment can efficiently measure our local activities without adding additional burden. I believe the FDIC requirement for community development for banks between $250 million and $1 billion is more flexible and more appropriate than the large bank investment test. Through this proposal rural banks will be able to meet the special needs of their communities by expanding the definition of community development. As Bankers we understand the need for regulatory requirements. As regulators we hope that there is an understanding that regulatory requirements should be meaningful but measured. Excessive regulations only detract from community bankers ability to attend to the needs of their community. Thank you for the opportunity to comment on this proposal. Sincerely, |
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| Last Updated 11/22/2004 | regs@fdic.gov | |