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


Bank of Wisconsin Dells

From: Gary Gilliland [mailto:jleeg@dellsbank.com]
Sent: Friday, September 17, 2004 2:28 PM
To: Comments
Subject: Streamlined CRA Exam; RIN number 3064-AC50

Gary Gilliland
PO Box 490
Wisconsin Dells, WI 53965-0490

September 17, 2004

Comments to FDIC

Dear Comments to FDIC:

As a community banker, I join my fellow community bankers throughout the
nation in strong support of the FDIC's proposal to increase the asset size
limit of banks eligible for the streamlined small-bank CRA examination. I
also strongly support the elimination of the separate holding company
qualification.

The proposal will greatly alleviate unnecessary paperwork and examination
burden without weakening our commitment to reinvest in our communities.
Reinvesting in our communities is something we do everyday as a matter of
good business. My community bank will not long survive if my local
community doesn't thrive, and that means my bank must be responsive to
community needs and promote and support community and economic
development.

Making it less burdensome to undergo a CRA exam by expanding eligibility
for the streamlined exam will not change the way my bank does business.
In fact, it will free up human and financial resources that can be
redirected to the community and used to make loans and provide other
services.

It is important to remember that the streamlined CRA exam is not an
exemption from CRA. It is a more cost effective and efficient CRA exam.
Banks subject to the simplified CRA exam are still fully obligated to
comply with CRA. Just as now, community banks would continue to be
examined to ensure they lend to all segments of their communities,
including low- and moderate-income individuals and neighborhoods. It just
doesn't make sense and is inequitable to evaluate a $500 million or $1
billion bank using the same exam procedures as for $100 billion or $500
billion bank.

In my opinion, our bank would be better off trying to truly reinvest
dollars locally to support our own market area rather than spending
resources trying to find "qualified investments" just to satisfy a
requirement of the large bank CRA exam. Such investments might be hard to
find anyway. For this reason, I find that the FDIC's proposed community
development requirement for banks between $250 million and $1 billion is
more flexible and more appropriate than the large bank investment test.
The advantage to this proposal is that it continues to focus on community
development, but considers investments, lending and services. It would
let community banks pursue community development activities that both meet
the local community's needs and make sense in light of the bank's
strategic strengths.

Similarly, the proposal will help rural banks meet the special needs of
their communities by expanding the definition of "community development"
so that it includes activities that benefit rural residents in addition to
low- and moderate-income individuals. Rural banks are frequently called
upon to support needed economic or infrastructure development such as
school construction, revitalizing Main Street, or loans that help create
needed or better-paying jobs. These activities should not be ineligible
for CRA credit because they do not benefit only low- or moderate-income
individuals.

The FDIC's proposed changes to CRA are needed to help alleviate regulatory
burden. By easing regulatory burden, it will make it easier for community
banks like mine to continue to provide committed service to local
communities that few other financial service providers are willing to do.

Thank you for considering my views.

Sincerely,

Gary L. Gilliland, Chairman, President & CEO of Bank of Wisconsin Dells

 

Last Updated 09/28/2004 regs@fdic.gov

Last Updated: August 4, 2024