FDIC Federal Register Citations

From: Michael
Sent: Thursday, September 09, 2004 2:39 PM
To: Comments
Subject: RIN number 3064-AC50

How does one determine if a bank is a community bank or a large bank? Can
you really look at just the size of the bank to tell? I don't think so. This change relieves the burden of collecting excess data from financial institutions that are otherwise doing a good job of being non-discriminatory, working towards improving their communities and sticking to the spirit of the Community Reinvestment Act.

Collecting the income and revenue and geographic location of every business and farm loan an institution makes costs our financial institutions both time and money that could be better spent working towards improving the community around them.

I fully support raising the bar separating the small bank from the large bank to a far more clearer level. I support giving the larger community banks the opportunity to redirect their attention from collecting data to doing the right thing.

I recommend that these insitutions continue to evaluate their community development efforts, their levels of lending within their community, and that we continue to ensure that no institution intentionally avoids lending to low to moderate income communities. I do not feel that requiring extensive paperwork is necessary to achieve the desired goal inherent in the Community Reinvestment Act.

Michael A. Peresta