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FDIC Federal Register Citations



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FDIC Federal Register Citations

From: Dan Stegall [mailto:stegad@plantersbank.net]
Sent: Monday, October 04, 2004 11:08 AM
To: Comments
Subject: RIN 3064-AC50

Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N. W.
Washington, D. C. 20429

Re: RIN 3064-AC50
Community Reinvestment Act (CRA)

Dear Mr. Feldman:

I am writing to comment on the FDIC's proposed changes to its CRA regulation. I applaud the proposal to raise the definition of 'small bank' for purposes of determining those banks eligible for the streamlined examination standards. Arguments in favor of such a change are compelling and I urge the FDIC to finalize its proposal at the earliest possible time.

CRA compliance costs are disproportionately higher on community banks that currently do not qualify for the streamlined test. We do not possess the resources that larger banks have to address this issue. In addition, lifting the regulatory burden will not affect the loans that we make in the communities that we serve, including low and moderate income areas.

Our bank, by the very nature of its business lends to all segments of the community. It is too difficult to acquire earning assets to exclude any segment from our lending even if it were not the right thing to do. We prosper when our total community prospers and raising the threshold will not reduce CRA loans, it will only reduce unnecessary paperwork and costly red tape.

As a practical matter, our bank finds it very difficult to compete with larger banks for qualified investments. The large bank test with its investment component simply does not work for a bank our size. Consistent with the FDIC's stated goal of reducing the regulatory burden where appropriate, the CRA regulation should be amended as proposed.

Sincerely,

William D. Stegall
President and CEO
Planters Bank and Trust

Last Updated 10/12/2004 regs@fdic.gov

Last Updated: August 4, 2024