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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

NAUGATUCK SAVINGS BANK

Mr. Robert E. Feldman
Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, D. C. 20429

Subject: RIN Number 3064-AC50

Dear Mr. Feldman,

We would like to make the following comments on proposals to change the regulations governing the Community Reinvestment Act.

Naugatuck Savings Bank is a $600 million mutual savings bank and has committed to donate 10% of pre-tax income into the Naugatuck Savings Bank Foundation which the bank formed in 1998. Currently the foundation has over $5 million in assets and will provide grants of over $230 thousand in 2004 to community based non-profit organizations. The Foundation is truly a community asset which will provide funding to non profit groups in perpetuity.

Comment 1: Should the small bank definition be increased to $1 billion without adding a community development criterion and subject these banks to the existing streamlined performance criteria applicable to banks with assets less then $250 million?

The bank is in favor of increasing this limit to $1 billion and strongly opposes adding any new community development criterion. The bank cannot compete in our markets with the large regional and national banks in meeting the investment criterion of the CRA regulations. Additionally, we do not have the resources or expertise to evaluate and manage these investments.

Comment 2: Instead of adding a community development criterion for small banks between $250 million and $1 billion under the current proposal, should the FDIC instead apply a separate community development test in addition to existing streamlined performance criteria applicable to small banks to evaluate community development activities of such banks?

As noted in Comment 1, the bank is not in favor of adding new community investment criterion, however, if the FDIC does develop new criterion we strongly encourage you to include the value of both the assets of a foundation and the annual giving of a foundation funded by a bank in the evaluation. The FDIC currently lacks any direction in regards to foundations and their value to the community.

In Naugatuck Savings Bank’s case, given the bank’s current projections the bank’s foundation will grow to over $11 million within 5 years and provide the community annually with over $500 thousand in contributions. This has a significant positive impact on the community and should be favorably and highly rated in the performance evaluation. Many banks similar in size and capital structure have created and funded like foundations in their communities.

Comment 3: If a new community test is imposed, how should these activities be weighted in assigning a performance rating?

The bank feels both the assets of a Foundation and the annual contributions to the community should be given a significant weight when assigning a performance rating.

Comment 4: How should the ratings of both the existing streamlined performance rating and the community development test be weighted in assigning an overall performance rating?

The bank feels strongly that our commitment to the community in donating close to $1 million a year into the foundation is commendable and shows our strong commitment to the communities we serve. It is unique and exceeds the commitment made by larger banks who receive outstanding ratings based on achieving higher scores on the current investment and service tests.

Clearly, committing 10% of pre-tax earnings needs to be given a significant weight when assigning the overall CRA performance rating.

Please consider these comments when drafting the proposed changes to the Community Reinvestment Act regulations.

Sincerely,

Nancy D. Carlson
Branch Manager / Bank Officer

 

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

Last Updated: August 4, 2024