Any rumors as to when they are likely to make a decision on the Large bank Small bank designation?

Lots of flack flew their way with the suggested changes. I'd sit pretty as whatever you are, or might soon become and wait it out. It seems to be up in the air at this point. Interesting though...The freaking OTS is now trying the "rural" goober (up for comments). Sheesh what's up with these folks!

At least they are trying to make changes. OCC is doing nothing

Why can't you be happy for those of us fortunate to have the OTS as a regulator? There has always been different rules and regulatory focus by regulator. I think the goal of the OTS is for banks to concentrate on making loans.

Making loans is not your only responsibility, you are also supposed to work on getting an Outstanding CRA rating. Granted, it doesn't mean much in the real world, but it demonstrates to the regulators/community that you are trying. The OTS is losing its focus, forgetting about the little guy!

You know, this is exactly why I think that now that they have done something to get the law enforcement groups to all communicate they should do something to get the regulatory groups doing the same. Imagine how much easier all of this would be if the OCC, FDIC, and OTS all reported to someone who made them all have the same focus and rules!

Michael, I agree with you on all the regulatory agencies working together but just look at the FACT ACT. In my opinion we don't have all the regulations yet because they are all trying to coordinate them and probably can't agree on a number of issues!!!

We're in the middle of a large bank CRA with the fdic and it is absolutely incredible the info they are looking at to dertemine if we are meeting the credit needs of our communities. The three tests conjured up by the feds is absurd to say the least but doable. Reform is so needed, we're so short on manpower as compared to the really large banks it hurts. I'm in favor of the increased limits. Hey, let's face it, if you're not doing your part to help the community, the competition will eat you alive. I believe that our open market credit system does work and that the regs. need a face lift, i.e. HMDA is the biggest bureauratic "pile" that needs to be addressed, its out of control. Our industry needs some serious reg. reform. Too many overlapping regs. and some that are so out dated they need to simply be laid to rest. (NO RANT PURE FACT!)

I'm not happy for you Chris, because changes to the regulation cause problems for both the people we hope to serve, and the bank's that are effected by the changes.

CRA is confusing enough as it is to most of the people I talk with (hence this forum) If we have different rules from different regulators, it just makes it worse. In addition, it confuses the heck out of our clients. Fair Lending is fair lending right? The reg is the same, no matter the agency doing the exam. Why on earth should we muck up the works and make CRA different?

One more thing...the completely stupid change regarding rural areas puts you at a competitive advantage to those of us who are not regulated by OTS or FDIC. While I have to make the effort to serve LMI people and geographies, you can start a new program to serve professionals...lets say doctors in rural communities. Sure they're high income and danged easy to lend to, so you can make a whole lot of dough without much effort. Oh and by the way...rural has not been distinctly defined, so for me that means my competition can specialize in high income lending programs in nine of my ten assessment areas which are rural in nature. I on the other hand, have to work to provide the same type of loan to LMI residents of these communities. The loans take more time, more effort, and more training to provide than a slam dunk home purchase loan to a doctor. They are typically at lower interest rates, and require more monitoring and servicing. My costs are higher, your costs are lower, and the doctor would have been able to get the home loan anyhoo, so why tie it to CRA?

The competitive advantage continues when you look to raising the thresholds too high. I was all for $500 million, but a billion, regardless of holding company, now that's just silly. It erodes the very nature of CRA.

CRA isn't a hard regulation to be successful at if you understand the reg. It provides a much needed service to a population that is ignored in favor of those deals to the doctors that are quick and easy. It's a fair reg the way it is currently written. I'm glad the OCC has continued to show some good sense and leave the reg alone. And...I'm not happy for my fellow man, because while I like many of you, and enjoy our discourse, if you're in my market, and you're my competition, I want us both to be operating under the same conditons, and then let the best bank win!

As it see it, the reg. just promotes the existence of a bureaucracy that has not kept pace with the 21st century. We have internet banks now and banks which due to attrition have grown defacto and are now faced with the "big bank" challenges. The resources of a $500MM bank do not nearly compare to that of a $1.00 billion institution. I can appreciate the self-preservation you're dealing with, but things change and this is just one of many that need reform. I'm for the increase in the threshold, at the same time I also agree that a level playing field is also needed.
More complicity only adds fuel to the raging fire.

First, I just spoke to a FRB lawyer today who told me don't hold your breadth waiting for any changes.
CRA is basically expects a bank to prove it is meeting the need for credit services in its market. It's as simple as that. The truth is that there are some very good software programs out there like QuestSoft (I don't work for them or own them, but I have a number of clients who use them) that cost less than $1,000 per year to interface with your LOS and prepare data for regulatory submission. So data collection needn't be expensive. This isn't to say there isn't a need for refining and improving some areas of the regulation, but on whole, it is a reasonable regulation. One of the benefits is that there is an abundance of market data about your competition and the borrowers. Smart bankers have stopped complaining about the regulation and started exploiting the valuable market data to improve their market share. There are plenty of good sources for that data at a very affordable price. You can get detailed HMDA mortgage market data showing market rank and market share of all lenders anywhere in your state for less than a $1,000. Ditto for CRA small business data. A good CRA officer will not only help his/her bank get good compliance performance ratings, they will concomitantly show their management the opportunities that exist to improve bank profit performance. I've seen community bankers eyes go wide open when they study the data and see the opportunities the data reveal to them.
One of the problems with the proposed changes is they would eliminate a lot of banks from reporting loan data, but not exempt them from performance. But, having eliminated all the loan data from banks under $1 billion, the regulators have eliminated valuable peer data making it more difficult to know how the smaller banks compare to their peers.