Montgomery Bank
August 24, 2004
Robert
Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal
Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
RIN: 3064-AC50
Dear Sir:
I am writing on behalf of Montgomery Bank in support of the following
FDIC proposed rule changes:
a. change the
definition of "small bank" to raise the asset
size threshold to $1 billion with no consideration of holding company
ownership;
b.
add a community development activity criterion to the
streamlined evaluation method for small banks with assets greater
than $250 million
up to $1 billion; and
c.
expand the definition of "community development" to
encompass a broader range of activities in rural areas.
Montgomery Bank applauds the Office of Thrift Supervision and now
the FDIC in their proposal to raise its CRA threshold to $1 billion.
This action will reduce regulatory burden for smaller institutions
and allow them to allocate their resources to better use. It is in
the best interests of the banking industry to have all financial
institutions operating under the same set of rules as adopted by
the OTS and now proposed by the FDIC. We would also encourage the
OCC and Federal Reserve to follow suit.
The time commitment
required by the paperwork and administrative efforts involved in
CRA data
collection, reporting, reviewing, preparing
for examinations, etc is large. The amount of new regulations imposed
on the banking industry in the past few years — especially
with new privacy regulations, USA PATRIOT regulations and increased
Bank Secrecy Act emphasis — has increased the regulatory burden
on banks with no relief. The costs associated with complying with
regulations eventually are passed onto bank customers.
By raising the threshold, community banks would not be exempt from
CRA, but would continue to serve their communities and free up some
of their already-stressed resources devoted to complying with laws
and regulations.
Sincerely,
Troy L. Wilson
Chief Executive Officer
Montgomery Bank
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