FDIC Federal Register Citations

VIA EMAIL

Dear Mr. Feldman:

I am responding to the request for comments regarding the proposed revisions to the FDIC Policy STatement on Minority-Owned Depository Institutions.

Overall, I believe the policy revisions represent a progressive step that will benefit the community of FDIC-insured institions that are minority held, and that this will be a positive move for the agency.

I would recommend a couple of modest changes from the draft proposal, as follows:

1. Eligibility should be consistent with US Treasury's Minority Bank Deposit Program (MBDP), and the FDIC should accept Treasury's certification in that regard. This would eliminate redundant certification procedures for the affected institutions and streamline certification for the agencies.

2. The requirement of certain reporting by the designated institutions should be carefully examined, and created to mirror existing reporting requirements of the Treasury Program (s) (MBDP or Community Development Financial Institutions Fund, (CDFI)). Most of these institutions are already over burdened with reporting, and it would be counterproductive in many cases to add additional reporting burdens.

3. I would further encourage the FDIC to adopt an "advisory board" of minority bank officials to provide additional guidance to the agency in administering this program. One of the sources of such a board may be the National Bankers Association (Norma Alexander Hart, President; 1513 P Street NW; Washington, DC; 202-588-5432)

4. Additional information on the type and level of technical assistance to be provided would be helpful in evaluating the proposed changes. I would also encourage the agency to be certain that the designated National and Regional Coordinators are directed to be proactive in seeking out minority institutions and offering the technical assistance being proposed, as well as to create an atmosphere of two-way dialog with them and the NBA to determine what kinds of assistance would be most beneficial.

5. It would be important to proactively seek out qualified minority institutions and individuals that may have an interest in acquiring a minority-owned institutions, and to frequently update that list (3-4 times per year).

Thank you for the opportunity to comment.

Sincerely,
Robert L. McKean
President and Chief Executive Officer
Albina Community Bank
2002 NE Martin Luther King Jr. Blvd.
Portland, Oregon 97212
(503) 288-7280