TEXAS BANKERS ASSOCIATION

Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Fax: (202) 898–3838
comments@fdic.gov

RE: Proposed Revisions to the Community Reinvestment Act Regulations

The Texas Bankers Association (“TBA”) appreciates the opportunity to comment on the Federal Deposit Insurance Corporation’s (“FDIC”) proposal to enlarge the number of banks and saving associations that will be examined under the small institution Community Reinvestment Act (CRA) examination. TBA represents the interests of more than 600 financial institutions in the state of Texas. A sizable number of these banks are between $250 and $1 billion in assets and would benefit from the additional relief provided by reducing the compliance burden.

While regulatory burden weighs on financial institutions of all sizes, it falls heaviest on community banks. The FDIC’s proposal to reduce this burden for community banks is both timely and necessary. This proposal is a major step towards an appropriate implementation of the CRA and should greatly reduce regulatory burden on those institutions newly made eligible for the small institution examination, and TBA strongly supports this proposal.

While community banks will still be examined under CRA for their record of helping to meet the credit needs of their communities, these change will eliminate some of the most problematic and burdensome elements of the current CRA regulation from community banks that are drowning in regulatory red-tape.

We urge the FDIC Board to approve the proposed increase to $1 billion in the size of the institutions eligible for the small bank CRA examination. Thank you for the opportunity to present our views. If you need additional information, please feel free to contact me at (512) 472-8388.

Sincerely,

B. Scott Daugherty
Assistant General Counsel