FDIC Federal Register Citations

From: John Dagley [mailto:jdagley@cbtwaco.com]
Sent: Wednesday, October 13, 2004 12:14 PM
To: Comments
Cc: Steve Hoag
Subject: RIN Number 3064-AC50

Mr. Robert Feldman
Executive Secretary
ATTN: Comments/Legal ESS
FDIC
550 17th Street, NW
Washington, DC 20429

Dear Mr. Feldman:

I am Senior Vice President & Trust Officer of Community Bank & Trust, located in Waco, Texas, a central Texas community of over 100,000 residents. Our bank is $270,000.00 in assets and is already subject to large bank CRA exam. I am writing to strongly support the FDIC’s proposal to raise the threshold for the streamlined small bank CRA exam to $1 billion without regard to the size of the bank’s holding company. This would greatly relieve the regulatory burden imposed on many small banks such as our bank under current regulation, which are required to meet the standards imposed on the nation’s largest $1 trillion banks. I understand that this is not an exemption from CRA and that our bank would still have to help meet the credit needs of its entire community and be evaluated by our regulator.

I strongly oppose making the Community Development criterion a separate test from the bank’s overall CRA evaluation. For a community bank, CD lending is not significantly different from the provision of credit to the entire community. The current small bank test considers the institution’s lending in its community. The addition of a category of CD lending (and services to aid lending and investments as a substitute for lending) fits well within the concept of serving the whole community. A separate test would create an additional CD obligation and regulatory burden that would erode the benefit of the streamlined exam.

In conclusion, I believe that the FDIC has proposed a major improvement in the CRA regulations, one that much more closely aligns the regulations with the Community Reinvestment Act itself, and I urge the FDIC to adopt its proposal, with the recommendations above. Thank you for your consideration of my opinion.

Respectfully,

John E. Dagley
Senior Vice President & Trust Officer
Community Bank and Trust
Waco, TX