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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

FIRST NATIONAL BANK OF GILLETTE

From: FNB Operations [mailto:fnbop@fnbgillette.com]
Sent: Friday, September 17, 2004 1:23 PM
To: Comments
Subject: CRA Proposal

September 17, 2004

To: FDIC
From: First National Bank of Gillette, Wyoming

This is to express our strong support for the FDIC proposal to increase the threshold for small banks to $1 billion for the Community Reinvestment Act.

First National Bank of Gillette is located in a small community in Wyoming with a population of approximately 20,000. Our community is remotely located from larger communities by approximately 150 miles in any direction. We are the only home owned bank in the community and continue to compete with the larger banking organizations that operate branch office in Gillette, including Well Fargo, Community First and U S Bank. We are a single unit bank with no branches and our defined CRA trade is Campbell County, of which Gillette is the principal community. Our entire outreach is to our local community regardless of the activity whether providing banking products and services or participating in local community organizations. It is our local community that supports our organization. Without our local community we would not exist. Additional compliance burdens imposed on our bank from the $250 million threshold provides no direct benefit, only increasing additional documentation requirements to reflect compliance.

We also strongly agree with the proposal opposing the community development criterion a separate test from the bank's overall CRA evaluation.

Our bank has historically participated in various programs intended to provide community development support including participation in the state's housing authority program to government supported programs of FHA, VA and SBA lending products. The bank has financially supported the local community development organization with both financial support and participation on boards by bank officers.

Again, further regulation here only increases the regulatory burden cost and likely would provide no significant improvement in the overall community development activities.

We were extremely disappointed when the proposal to increase the threshold was recently overturned. We have expressed our disappointment and concern to our regulator, the OCC.

There are may communities like Gillette where CRA has no real influence. Such organizations must rely on there local community for growth and profitability. Without supporting your local community you would not exist. No CRA regulation changes this fact.

Last Updated 10/01/2004 regs@fdic.gov

Last Updated: August 4, 2024