If these cost estimates are even remotely accurate in the NPR, and we all know Washington tends to underestimate costs, we are facing an absurd regulatory cost increase, particularly for current ISBs. From page 112:
"the FDIC estimates that the complying with the CRA would pose $93,000 in annual costs for small, FDIC-supervised entities subject to the small bank performance standards, and $665,802.45 in annual costs for small, FDIC-supervised entities subject to the new general performance standards."
To parse that regulatory speak into common language: banks under $500,000 in assets would see annual costs increase $93,000, and bank $500 million to $1.284 billion would see $665,802.45 in annual cost increases. What are they thinking? An ISB is going to spend $2 million per three-year exam cycle on this proposal? How far beyond insane is that? How is that level of spending going to help us serve LMI individuals?