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FDIC Federal Register Citations Patriot National Bank September 10, 2004 Robert E. Feldman, Executive Secretary Re: Community Reinvestment, RIN number 3064-AC50; Dear Mr. Feldman: As a community banker, I strongly support the FDIC's proposal to increase the asset size limit of banks eligible for the streamlined small-bank CRA examination. The FDIC proposal will eliminate unneeded paperwork and effort without weakening our 'commitment to reinvest in our communities. Making it less of a burden to undergo a CRA exam will not change the way my bank does business. We will instead have more time and resources to meet the financial needs of our community through loans and other services to all income levels. The small bank CRA examination is not an exemption from CRA. It is just a more efficient way of ensuring that we lend to all segments of the community, including low-and moderate-income individuals. The definition of "qualified investments" in the large bank CRA examination is too limited making qualified investments are hard to fine. Sometimes eligible investments do not benefit the community of the investing bank. This is wrong. Resources are taken away from the bank's community. Communities would be better off if banks could make investments that
benefit their community. The FDIC's proposed community development
requirement for banks between $ 250 million and $ 1 billion is more flexible
and more appropriate than the large bank investment test. The FDIC proposal also helps rural banks through the expanded definition of "community development" to include infrastructure investments that benefit all income levels. The FDIC's proposed changes to CRA are needed to help limit regulatory burden. This will make it easier for community banks like mine to continue to provide committed service to local communities. Thank you for your consideration. Sincerely,
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| Last Updated 10/23/2004 | regs@fdic.gov | |