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

FIRST CITIZENS NATIONAL BANK

From: Doug Whitten [mailto:dwhitten@firstcitizensbank.com]
Sent: Thursday, September 16, 2004 9:36 AM
To: Comments
Subject: RIN No. 3064-AC50

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

I support the FDIC proposed increase of the threshold for the small bank streamlined CRA examination from under $250 million in assets to under $1 billion, without regard to the size of the bank’s holding company. Our bank is a $500 million dollar bank in rural north central Pennsylvania. We have and will continue to have a strong interest in supporting community development. We do this not because it is the law but because it is good business. The reporting and tracking burden only detracts from our ability to support our communities.

I strongly support the FDIC’s proposal to change the definition of “community development” from only focusing on low- and moderate-income area residents to including rural residents. This change will go a long way toward eliminating the current distortions in the regulations that result in a small rural bank being told to invest in regional affordable housing bonds for an urban area not in the bank’s community.

I strongly oppose making the Community Development (CD) criterion a separate test from the bank’s overall CRA evaluation. For a community bank, CD lending is not significantly different from the provision of credit to the entire community. The current small bank test considers the institution’s overall lending in its community. The addition of a category of CD lending (and services to aid lending and investments as a substitute for lending) fits well within the concept of serving the whole community. A separate test would create an additional CD obligation and regulatory burden that would erode the benefit of the streamlined exam.

In conclusion, 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, with the recommendations above. I will be happy to discuss these issues further with you, if that would be helpful.

Douglas W. Whitten
VP Operations Division Manager
First Citizens National Bank
1163 South Main Street
Mansfield, PA 16933
 

Last Updated 09/29/2004 regs@fdic.gov

Last Updated: August 4, 2024