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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations



Community Bankers Association of Ohio

September 1, 2004

Scott M. Polakoff
Regional Director
Federal Deposit Insurance Corporation
500 West Monroe Street
Suite 3500
Chicago, IL 60661

Dear Scott,

The Community Bankers Association of Ohio (CBAO) is Ohio's oldest statewide financial trade association representing Independent Community Bank and Thrift Institutions. CBAO Members serve their communities through 625 locations, with over 7,000 employees in Ohio. Members collectively hold $23 Billion in assets, $18 Billion in insured deposits and $15 Billion in net loans.

We appreciate the FDIC issuing a new proposal to solicit additional comments on the impact of changing the definition of a small bank for purposes of CRA to include those with total assets of up to $1 billion, regardless of holding company affiliation.

The CBAO and its Financial Membership strongly supports your proposal to increase the size limit for community financial institutions eligible for the small bank streamlined Community Reinvestment Act Examination from $250 mullion to $1 billion. We also support establishing a community development test which would permit more choice for our financial institutions to be evaluated based upon their community development lending, qualified investments or community development services, as opposed to all three. This proposal would also help our community focused financial institutions to better compete with multibillion-dollar financial institutions for qualified investments.

The FDIC proposal would replicate the recently finalized OTS rule, which raises the limit to $1 billion, effective October 01, 2004.

The proposed changes will not undermine the intended purpose of CRA and would ease the paperwork and examination burden on approximately 280 community financial institutions in the state of Ohio.

Sincerely,
Robert L. Palmer
President and Chief Executive Officer

 

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

Last Updated: August 4, 2024