FDIC Federal Register Citations

It is important that the requirement for community reinvestment by banks not be diluted. As banks continue to consolidate, management is moved from smaller communities to larger ones and the personal involvement of the bank in its community decreases. Decision making no longer is influenced by community considerations.

Small businesses are currently being adversely affected by the movement of loan approval from local district offices to consolidated locations. Only those who fit a pre determined criteria will be able to obtain an SBA guarantee, while those with special circumstances, even though the loan would be viable, will not receive guaranteed funding.

The same thing will happen to smaller communities. We already see it in the daily activities of our smaller banks that have consolidated. Without the CRA, I believe we will see even less involvement of these banks in our communities at a time when rural America needs all the reinvestment it can get.