FDIC Federal Register Citations

Fidelity Bank

From: Allan Houston [mailto:ahouston@fidelitybankonline.com]
Sent: Friday, September 17, 2004 1:41 PM
To: Comments
Subject: RIN #3064-AL50

Robert E. Feldman, Executive Secretary
Attn: Comments
Federal Deposit Insurance Corporation
550 17th Street North West
Washington, DC 20429

Subject: Community Reinvestment RIN 3064-AC50

Dear Mr. Feldman:

I am the SVP of Residential Lending and CRA Officer at the Fidelity Bank, Fitchburg, MA, a $300 million bank. I believe the CRA revisions are both welcome and appropriate. I would however urge the FDIC to adopt a $500 million up to $1 billion threshold for small banks to have a community development criterion. I think this is appropriate understanding the level of resources of our Bank and of Bank’s our size coupled with the fact that the current small bank lending criterion adequately captures the most vital evidence of a small bank’s contribution to the community it serves, lending.

Also, for purposes of lowering the regulatory burden of the law, requiring a community development test at a level lower than $500 million substantially lessens the benefit of the revisions.
Additional banks under $500 million now hold about the same percent of overall industry assets as community banks under $250 million did a decade ago when the revised CRA regulations were adopted, so this adjustment in the CRA threshold is appropriate without an additional criterion.

In conclusion the FDIC proposal is welcome and one that continues to align the interest all concerned. I do believe that setting the thresholds as indicated above would accomplish the desired regulatory benefits without diminishing the value of the law to the communities being served.

Sincerely,
Allan Houston