FDIC Federal Register Citations

October 20, 2004

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

Dear Sir:

As a community banker, I join my fellow community bankers throughout the nation in support of the FDIC’s proposal to increase the asset size limit of banks eligible for the streamlined small-bank CRA examination. I also support the elimination of the separate holding company qualification.

The proposal 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. As a community bank, we are responsive to the needs of our community and we promote and support community and economic development.

It is important to remember that the streamlined CRA 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. Just as now, community banks would continue to be examined to ensure they lend to all segments of their communities, including low- and moderate-income individuals and neighborhoods.

The FDIC's proposed community development requirement for banks between $250 million and $1 billion is more flexible and more appropriate than the large bank investment test. The advantage to this proposal is that it continues to focus on community development, but considers investments, lending and services. It would let community banks pursue community development activities that both meet the local community's needs and make sense in light of the bank's strategic strengths.

Thank you for considering my views.

Valerie M. Quiett
Compliance Officer
Mechanics and Farmers Bank
2634 Durham-Chapel Hill Blvd.
Durham, N.C. 27707