FDIC Federal Register Citations

September 21, 2004

Robert E. Feldman — Executive Secretary
Federal Deposit Insurance Corporation
550 17th St., N.W.
Washington, D.C. 29429

Re: Change in CRA threshold of $250 million to $1 billion in assets.

Dear Mr. Feldman:

I am the President of a truly small, mutual, state chartered savings and loan institution with just over $90 million in assets. I am totally opposed to raising the threshold from $250 million to $1 billion to qualify as a "small institution" under the CRA guidelines. There is no way you can compare the operations of an institution that is approaching $1 billion dollars in assets to one with less than $250 million in assets. Small institutions like ours are very committed to lending to all sectors of our communities. We are small enough that if we were to fail to properly serve the members of our communities, it would almost certainly result in our failures.

If a change must be made, I feel that the original target of $500 million that was proposed in February of 2004 would be a more realistic threshold for an institution to be described as a "small institution."

If the threshold is changed to $1 billion, then I feel that any institution with less than $250 million in assets should be exempted from CRA as we are already committed to meeting the needs of our communities. Our institution has never failed to receive anything less than an "Outstanding" rating from its CRA evaluations. We didn't need the Community Reinvestment Act to get us to properly serve our communities; we do it from the knowledge that what is good for our communities is good for us. The 6.7% of us that have assets of less than $250 million would certainly welcome the regulatory relief.

Thank you for considering my thoughts on this matter.

Sincerely,

Charles R. Bryant, Jr.
President
Rio Grande Savings and Loan Association
Monte Vista, CO