FDIC Federal Register Citations

From: Stephen Godar [mailto:stephengodar@fsbmail.net]
Sent: Tuesday, September 14, 2004 7:30 AM
To: Comments
Subject: RIN3064-AC50 (CRA)

Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
500 17th Street NW
Washington, DC 20429

RE: Community Reinvestment Act Proposal
RIN 3064-AC50

Dear Mr. Feldman:

I appreciate being able to comment on your proposed changes to the Community Reinvestment Act (CRA). Please accept this letter as support for your proposal to change the small bank asset threshold from $250 million to $1 billion.

As a community banker I understand the regulatory burden CRA places on our industry. Continuing costs of software, software upgrades and personnel needed to comply with the data recording requirements of CRA alone use up resources that could be better spent on the development of the community. There are a limited number of qualified investments in our communities. Billion dollar institutions have the money and manpower required to be successful in gaining these investments over smaller institutions. Yet, when regulatory agencies examine us under CRA, we are compared to those institutions as our “peers”. There is just no comparison.

I urge the FDIC to take this opportunity to ease the burden of this regulation on our community banks. Therefore, I do not support the addition of any new community development tests that would further complicate this.

Thank you,

Steve Godar