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FDIC Federal Register Citations

LITCHFIELD BANCORP

From: Mark Macomber [mailto:macomber@litchfieldbancorp.com]
Sent: Tuesday, September 28, 2004 4:02 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50

Mark Macomber
President & CEO
Litchfield Bancorp
294 West Street
Litchfield, CT 06759

September 28, 2004

Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Dear Robert Feldman:

As a community banker, I am pleased to comment in support of the proposal issued by the FDIC that would amend the definition of a small institution to be a bank that is under $1 billion in assets. I believe that this change will provide much needed regulatory burden relief for community bankers and, representing Americas Community Bankers, I have testified before a House sub-committee to that effect. This is one example of regulatory burden relief that will really make a difference. I would much rather use the limited resources available to my bank to serve my community than to collect and maintain data and documents to prove to examiners that my bank is actually doing that which is its only option - serving all elements of the local community.

My bank is $170 million in assets, so today falls below the existing threshold. Our sister bank in Connecticut's only mutual holding company, Northwest Community Bank, is about $270 million in assets and falls above the threshold. There is virtually no difference in how we conduct our businesses or in our firm, proactive commitment to the communities we serve, yet Northwest is burdened, and that is the word, with excessive and largely meaningless paperwork. The requisite time and effort could be / would be better spent in productive matters.

Compliance with the Community Reinvestment Act is something we take very seriously at our bank. We don’t just believe it is the right thing to do; we believe it is the right business thing to do. No community bank can survive and compete without meeting the needs of its customers and communities.

It is absurd to think that a bank thousands of times larger than my own community bank should be examined using the same procedures. I strongly urge you to amend the definition of a small bank for CRA purposes to be an institution with less than $1 billion in assets, regardless of whether the bank is part of a holding company. This is a good proposal and is the right thing to do.

Thank you for considering my views and thank you for proposing this much need change.

Sincerely,
Mark Macomber
860-567-9401
President & CEO
Litchfield Bancorp

Last Updated 10/07/2004 regs@fdic.gov

Last Updated: August 4, 2024