FDIC Federal Register Citations

September 20, 2004

Mr. Robert E. Feldman
Attn: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Re: RIN Number 3064-AC50

Dear Sir or Madam:

I am writing on behalf of our community bank, its employees, and most importantly its customers. Our bank has $116 million in assets and a small staff of ten employees. The bank was chartered in 2002. I am writing to strongly support the FDIC’s proposal to raise the threshold for streamlined small bank CRA examination to $ 1 billion without regard to the size of the parent holding company of the bank.

As a community bank CEO in the Midwest when the small bank exception was first initiated several years ago, I know first hand the huge amount of employee and management time which community banks saved by not having to spend countless hours collecting documentation so we could prove to a bank regulator we were serving our community. By definition, community banks only reason to exist is to serve their community. Not doing so puts the continued existence of the bank into serious question.
The current small bank CRA examination procedures has allowed community banks like mine to spend time in a more productive way, lending to consumers and small business in our community and counseling clients in building a secure financial future. It is now time to raise the existing threshold and allow even more banks to create more value for their communities. Certainly in light of the consolidation within the banking industry the time has come to raise the threshold for the streamlined CRA examination procedures.

Reinvesting in our community is not a burden for our bank or for other community banks. However, regulation is a huge burden. In light of the recent study of bank regulatory burden, especially on community banks, I want to thank the FDIC for bring forth this proposal and offer my strongest support.

Sincerely,
Philip M. Burns
President