Skip to main content
U.S. flag
An official website of the United States government
Dot gov
The .gov means it’s official. 
Federal government websites often end in .gov or .mil. Before sharing sensitive information, make sure you’re on a federal government site.
Https
The site is secure. 
The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely.
Federal Register Publications

FDIC Federal Register Citations



Home > Regulation & Examinations > Laws & Regulations > FDIC Federal Register Citations




FDIC Federal Register Citations

FARMERS STATE BANK

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 the opportunity to comment on your proposal to increase the asset size threshold for small banks under the Community Reinvestment Act (CRA) from $250 million to $1 billion.

I applaud the FDIC for taking a leadership role among the agencies and recognizing the regulatory burdens being placed on community banks. With the passage of Check 21, USA PATRIOT Act, FACTA and changes to HMDA our already limited resources are stretched thin. Passage of this proposal would free up the costs of the CRA software, software upgrades and manpower needed for the data collection process alone, allowing us to apply some of these resources to the true intent of the CRA – providing low cost loans and services to members of our community.

With that being said, I do not support additional community development criterion be set for institutions between $250 million and $1 billion in assets. Those “freed up” resources I spoke of would need to be forced back into training and efforts necessary to comply with those new requirements. The new requirements would not serve the purpose of this proposal, which is to reduce regulatory burden. Instead, it would just create additional inconsistencies among the regulatory agencies.

We understand and support the spirit and intent of the CRA and pledge to continue our vital role in the development of our community. Our bank will not survive without a growing, thriving community. The CRA is by no means being repealed and therefore, we recognize our responsibilities remain.

Thank you for your consideration.

Gene R. Neighbor

Last Updated 09/25/2004 regs@fdic.gov

Last Updated: August 4, 2024