ots_mar2004_2004-04_cra.pdfComment letter opposing the proposed CRA
regulation would change the definition of “small bank” from any
institution with less that $250 million in assets and not part of a
holding company with over $1 billion in assets to include all
institutions with less than $500 million in assets regardless of
holding company size. This change will dramatically increase the number
of banks considered “small” that, for CRA purposes, are not examined
for their levels of community investment and services under the
streamlined small bank CRA examination.