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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. |
