February 17, 2011
To whom it may concern:
The proposal resulting from the Dodd-Frank Bill to have a registration process for community banks that take in municipal deposits and make municipal loans is unnecessary and burdensome. Who are the community banks that have caused any municipal issue with regards to deposits, loans, or securities advice? What deposits or loans between community banks and municipalities caused any issues for which the SEC believes registration is necessary? The deposits and loans between my bank, Greenfield Co-operative Bank, and municipalities in our part of Massachusetts are no different than what we offer to individuals and small businesses. The track record of our bank as can be seen in our regulatory filings shows sound, safe, conservative banking practices.
Greenfield Co-operative Bank, whom I help represent, is a state chartered mutual bank. As such in Massachusetts, all deposits are fully insured with no risk to the municipalities. Our bank is regulated by the State Bank Commissioner's Office, FDIC, as well as having both internal and external audits performed. The municipalities of Massachusetts are overseen but the State Department of Revenue (DOR) and must comply with the DOR's rules as well as pass scrutiny by the DOR and audit firms.
The risks posed by community banks are small and straightforward to municipalities. Big money center banks take in municipal deposits through their branching systems from many states that are not home to them and then use the deposits to fund their risky agendas such as the underwriting of brokered home loans. Meanwhile the local banks in the states and towns of the municipalities making the deposits are denied use of the taxpayer dollars in the deposits to help fund local home ownership and jobs. Registration for community banks that did not cause this mess and is just one more step in a series of roadblocks to keep community banks from tax dollars that could be kept and used locally.
How many thousands of banks will have to help pay for this system when they did not cause any of this and only a few big banks were at fault? This cost will further take away valuable resources from communities and their local banks that could be put to better use. What if the bank regulators and states actually reported violations committed by banks when dealing with municipalities to the SEC? After being reported the banks being cited would have to register, thereby creating a registry of violators? This would be analogous to the securities traders who are listed by the SEC in publications such as the Wall Street Journal when enforcement action is taken as a result of the traders' digressions? Bank regulators don't like bad press for any bank due to safety and soundness issues, however many of the traders whom this happens to now are with firms owned by the large commercial banks, thereby placing bad press and liability on the banks as it now stands. This alternative proposal would also creates a lot more transparency for the public and Congress using a process that is already in place.
Please consider another approach to any issues the SEC sees with banks that have caused financial issues with municipalities. It seems there are only a few banks that caused this yet all banks are being disciplined needlessly.
Respectfully submitted,
Eric A. Marsh
SVP, Treasurer & CFO