FDIC Federal Register Citations

Grabill Bank

13505 Main St.
Grabill, IN 46741
260-627-2143

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Re: RIN Number 3064A-AC50: FDIC Proposed Increase in the Threshold for the Small Bank CRA Streamlined Examination

Dear Mr. Feldman,

I am Director of Compliance, Internal Audit and Loan Review for Grabill Bank, located in a small farming community of around 1,000 residents. My bank has assets just over $500,000,000 and is subject to large bank CRA exam procedures. I am writing to strongly support the FDIC’s proposal to raise the threshold for the streamlined small bank CRA examination to $1 billion without regard to the size of the bank’s holding company. This would greatly relieve the regulatory burden imposed on many small banks such as my own under the current regulation, which are required to meet the standards imposed on the nation’s largest $1 trillion banks. I understand that this is not an exemption from CRA and that my bank would still have to help meet the credit needs of its entire community and be evaluated by my regulator. However, I believe that this would lower my current regulatory burden significantly.

I believe that the FDIC has proposed a major improvement in the CRA regulations, one that much more closely aligns the regulations with the Community Reinvestment Act itself, and I urge the FDIC to adopt its proposal.

Sincerely,

Michael M. Gonya
Director of Compliance, Loan Review and Auditing