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FDIC Federal Register Citations


FARMERS STATE BANK

From: Diane Foltz [mailto:Diane_Foltz@fsbmail.net]
Sent: Monday, September 13, 2004 12:10 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Dear Mr. Feldman:

I am writing on behalf of Farmers State Bank in Marion, Iowa. We are a $437 million institution with seven offices in our county. I appreciate being able to comment on your proposed changes to the Community Reinvestment Act (CRA).

In preparation for writing this letter, I took time to review some of the comments already posted to your site. As it is clearly expressed in most letters from community bankers, regulatory issues have placed a large burden upon our industry. USA PATRIOT Act, Check 21, CAN SPAM and FACTA are some of the new regulatory issues we have had to add to our workloads in just the past twelve months. In addition to that, we have had major changes to Regulation B and Regulation C along with minor changes to several other regulations. For Compliance Officers and Managers, it is getting more and more difficult to keep up with the never-ending changes and data reporting requirements. And, as you can see by looking at several of the comment letters, compliance is often just one of the many "hats" community bankers wear. Many times compliance duties are in addition to lending, BSA, security and/or internal auditing. I feel strongly that it is time to give banks some relief. With that being said I would like to express my strong support for reducing the regulatory burdens of CRA on financial institutions and increasing the small bank asset size threshold from $250 million to $1 billion.

More than one comment letter submitted seemed to think that by reducing the number of banks examined under the large bank rules, those banks would suddenly be relieved of all requirements under CRA. And, that suddenly our support for the communities in which we live and work would cease. This is absolutely untrue. No banker is disputing the importance of CRA. We know what our industry contributes is vital to our communities and that it must continue. Community banks will not survive if those communities don't thrive. However, banks could afford relief in the way of a less rigorous exam and eased reporting requirements. Ongoing costs of software and personnel required to maintain CRA data stretch already limited resources. This information is coded internally by most institutions and can be pulled if necessary instead of subjecting financial institutions to the excessive record keeping requirements of today. Also, many dwelling secured small business and small farm loans are covered and recorded under the new HMDA requirements. That data will show lending practices to minority and women owned businesses. I am not in support of the new community development test for institutions between $250 million and $1 billion, but if is the only way to meet in the middle, I will accept it as it is more flexible than today's requirements.

In conclusion, I would like to state that staff have told me how the joy of being in the banking industry is starting to slip away. We got into this industry to assist people with their financial needs only to end up afraid to do so with threats of violations and penalties looming from the many regulations we are required to comply with each day. I applaud the FDIC for taking a leadership role in addressing this issue and trying to make a difference in the industry.

Thank you.

Diane Foltz
Compliance Officer
Farmers State Bank



Last Updated 09/13/2004 regs@fdic.gov

Last Updated: August 4, 2024