FDIC Federal Register Citations

From: John Wassilak [mailto:jwassilak@fcnbanks.com]
Sent: Monday, October 18, 2004 2:46 PM
To: Comments
Cc: 'Regs.comments@occ.treas.gov'
Subject: RIN Number 3064-AC50

As a community bank, we support the FDIC proposal to raise the CRA streamlined small bank examination threshold to $1 billion. CRA examinations continue to show that community banks overall, meet the credit needs of the communities they serve. We also believe that the FDIC should adopt its original $500 million threshold without a community development(CD) criterion. Community Banks up to $500 million now hold about the same percent of overall industry assets as community banks up to $250,000 did a decade ago, when CRA was revised. We also oppose making the CD criterion on a separate test for CRA evaluations as the current small bank test already considers our overall lending in the community. This would create additional regulatory burden which defeats the purpose of a more streamlined exam. Since we are in a rural area, we also support the inclusion of rural residents in the definition of community development. With the level of bank regulation at an all time high, you have the opportunity to provide regulatory relief to community banks and at the same time, leave the intent of CRA in place.