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FDIC Federal Register Citations Peoples Savings September 13, 2004 Robert E. Feldman, Executive Secretary Re: Community Reinvestment, RIN number 3064-AC50; Dear Mr. Feldman: I am writing to tell you that, I join my fellow community bankers throughout the nation in strong support of the FDIC's proposal to increase the asset size limit of banks eligible for-the streamlined small-bank CRA examination. Our bank is $190,000,000 in assets and has already been contacted by the regulator in anticipation of us crossing the threshold. They have pointed out to us that the crossing of the threshold will put; greater reporting and compliance burdens on us and that we must start now in order toy comply. The proposal being considered will greatly alleviate unnecessary paperwork, and examination burden without weakening our commitment to reinvest in our communities. Reinvesting in our communities is something we do everyday as a matter of good business. My community bank will not long survive if my local community doesn't thrive, and that means my bank must be responsive to community needs and promote and support community and economic development. Making it less burdensome to undergo a CRA exam by expanding eligibility for the streamlined exam will not change the way my bank does business. In fact it will free up people and financial resources that can be redirected to the community and used to make loans and provide other services. It is important to remember that the streamlined CIA exam is not an
exemption from CRA.. It is a more cost effective and efficient CRA exam.
Banks subject to the simplified CRA exam are still fully obligated to comply
with CRA. The FDIC's proposed changes to CRA are needed to help alleviate regulatory burden. Without changes such as this, more and more community banks, like mine, will find they cannot sustain independent existence because of the crushing regulatory burden, and will opt to sell out. For many small towns and rural communities, the loss of the local bank is a major blow to the local community. By easing regulatory burden, it will make it easier for community banks to continue to provide service to local communities that few other financial service providers are willing to do. Thank you for considering my views. Sincerely,
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Last Updated 10/23/2004 | regs@fdic.gov |