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EVANS NATIONAL BANK
September 17, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50 (FDIC Proposed Increase in the Threshold for
the Small Bank CRA Streamlined Examination
Dear Mr. Feldman:
Evans National Bank is an 84 year old community bank with its main
office in Angola, New York, a community of less than 5,000 residents.
Our primary market area includes two counties in Western New York State,
both Erie and Chautauqua Counties. With assets of approximately $408
million, we provide a full range of financial services.
I am writing to strongly support the FDIC’s proposal to raise the
threshold for the streamlined small bank CRA examination to $1 billion
without regard to the size of the bank’s holding company. This would
greatly relieve the regulatory burden imposed on many small banks, such
as my own, under the current regulation, which are required to meet the
standards imposed on the nation’s largest $1 trillion bank. Up until
now, we have been considered a small bank for CRA examination purposes.
I understand that this is not an exemption from CRA and that my bank
would still have to help meet the credit needs of its entire community
and be evaluated by our regulators; however, I believe that this would
lower our current regulatory burden.
I also support the addition of a community development criterion to
the small bank examination for larger community banks. The new community
development criterion should be applied only to banks greater than $500
million up to $1 billion. As FDIC examiners know, it has proven
extremely difficult for small banks, especially those in rural areas, to
find appropriate CRA qualified investments in their communities.
I believe your proposal will be a major improvement in the CRA
regulations, and I urge its adoption.
Sincerely,
James Tilley
President and
Chief Executive Officer
Cc: The Honorable John D. Hawke, Jr. |
