FDIC Federal Register Citations

October 15, 2004

Robert E. Feldman, Executive Secretary
Attention: Comments / Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429

Re: Proposed Amendments to CRA

Dear Mr. Feldman:

In FIL- 108-2004, your agency asked banks to comment on the proposed amendments to the Community Reinvestment Act. One of the proposed amendments would change the definition of a small institution to mean an institution with total assets of up to $1 billion.

I serve as a Vice President & Branch Manager for a community bank that became a “large bank” under the CRA two years ago. Our institution has had to deal with the increased regulatory burden of data collection and reporting on its small business, small farm and community development loans for the last two years. This is very burdensome to community banks that make the majority of their loans inside their assessment areas.

Another issue involves the CRA examination process. Under the large bank CRA examination process, the investment test is difficult for a community bank to attain a satisfactory rating. We compete for suitable investments in our market with large regional and national banks that have an unfair advantage due to their size. These banks literally will spend whatever it takes to get suitable investments. This results in smaller institutions being at a disadvantage during exam time.

Our institution is in favor of changing the definition of a small institution to one with total assets of up to $1 billion without regard to the holding company assets.

Thank you for considering this matter.

Sincerely,

Doug Como
Vice President/Branch Manager