Skip to main content
U.S. flag
An official website of the United States government
Dot gov
The .gov means it’s official. 
Federal government websites often end in .gov or .mil. Before sharing sensitive information, make sure you’re on a federal government site.
Https
The site is secure. 
The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely.
Federal Register Publications

FDIC Federal Register Citations



Home > Regulation & Examinations > Laws & Regulations > FDIC Federal Register Citations




FDIC Federal Register Citations

KENNEBEC SAVINGS BANK

From: Andrew E. Silsby [mailto:asilsby@kennebecsavings.com]
Sent: Thursday, October 07, 2004 3:17 PM
To: Comments
Subject: Community Reinvestment: RIN number 3064-AC50

Andrew E. Silsby
Vice President & Senior Loan Officer
Kennebec Savings Bank
150 State Street
Augusta, ME 04330

October 7, 2004

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

Dear Robert Feldman:

As a community banker and our Bank's Senior Lender, 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 me and other community bankers. We crossed over the $250 million "large bank" mark a number of years ago and have found it difficult to make all the things that we do for our communities count toward the large bank tests. We do a lot for our communities in terms of donation and services, yet most of that does not count under the large bank tests. It seems that every week there is a new or additional regulation with which we must comply. 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 I am meeting the needs of my community.

Kennebec Savings Bank is a mutual savings bank located in Augusta, Maine. We are just under $500 million in assets and have about 75 employees serving the great Kennebec County area.

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. We believe in our community and in our customers and want to work with them to provide products and services that best meet their credit needs. We do not need a complicated examination process to show that we are complying with the law.

It is absurd to think that a bank thousands of times larger than my own community bank should be examined using the same procedures. Many of these big banks don't even contribute to the local high school yearbook or sponsor the local baseball team, yet they get an outsatnding CRA rating because they took investment dollars and put them into highly risky venture funds solely for CRA credit. 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.

Sincerely,
Andrew E. Silsby
207-622-5801
Vice President & Senior Loan Officer
Kennebec Savings Bank

Last Updated 10/13/2004 regs@fdic.gov

Last Updated: August 4, 2024