FDIC Federal Register Citations

Security National Bank of Omaha


From: Pam Zbylut
Sent: Friday, August 27, 2004 4:57 PM
To: Comments
Subject: RIN number 3065-AC50

RE: Proposal to Revise CRA

I want to express our bank's support for revisions to the Community Reinvestment Act that will (a) change the definition of "small bank" to raise the asset size threshold to $1 billion regardless of holding company affiliation; (b) add a community development activity criterion to the streamlined evaluation method for small banks with assets greater than $250 million and up to $1 billion.

Raising the threshold to $1 billion regardless of holding company affiliation does reduce regulatory burden for banks.

Evaluating community development activities as a separate component for banks in the $250 million to $1 billion asset category also reduces regulatory burden. Banks in the $250 million to $1 billion size may have difficulty receiving a "Satisfactory" on the lending, investment, and services tests due to limited resources (people/man-hours and money) as compared to mega banks and banks over $1 billion. Banks in the $250 million to $1 billion size may already be performing significant community development activities based on their size which may result in a Satisfactory rating under the new community development criterion to be added to the streamlined evaluation.

Thank you for your consideration of these comments.

Sincerely,

Pam Zbylut
Audit/Compliance Manager
Security National Bank of Omaha
Omaha, Nebraska