Country Club Bank
October 5, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Mr. Feldman:
I am writing
to you on behalf of Country Club Bank, n.a., located in Prairie
Village,
Kansas, a suburb of the Greater Kansas City Metropolitan
Area. The size of our bank is $425 million and therefore will be
subject to the large bank CRA examination requirements. Our growth
over the last 5 years caused us to be considered a ‘large’ bank.
We pride ourselves on being a hometown, locally owned bank, and
are somewhat taken aback to be considered large, just for having
exceeded the $250 million threshold. To be sure, we are as small
now as we were previously and are proud of being able to serve our
community with a personal and immediate response. We are ever mindful
of the various regulatory requirements by which one has to abide.
I wish we had the personnel available to perform a cost study as
to how much time and effort is being expended on regulatory issues.
Efforts that could easily be redirected to endeavors that would benefit
our community. It is, nonetheless, frustrating to think that an entity
of even $1 billion should be subject to the identical CRA requirements
as the multi-billion dollar banks which control the vast majority
of the nations deposits.
Therefore, we
support the FDIC threshold for streamlined CRA examination to all
banking
entities of under $1 billion. It would not be meaningful
to add a community development caveat to this formula as currently
suggested, however. One should allow the covered bank to meet its
community development criterion by engaging in any one type or combination
of community development activity, i.e. lending, investments, or
services – as opposed to separate tests for all three.
The recent New
York Times editorial suggesting that a change from the status quo
would be
a “drastic change that would allow
more than a thousand banks to back away from their community development
obligations”, is an opinion void of a reality check. A community
bank is called that because they are attuned to, and responsive to
the needs of the people. They do this without subjecting members
of their community to 800 numbers. Their involvement in their communities
goes well beyond any lending criteria.
To be sure, this letter is strongly in support of the increased
asset level for CRA examination as proposed by the OTS and now the
FDIC.
Sincerely,
William M. Teiwes
Executive Vice President – COO
Country Club Bank, n.a.
Cc: The Honorable John D. Hawke, Jr.
Comptroller of the Currency
Independence Square, 250 E Street, S.W.
Washington, DC 20551
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