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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

NEW HAMPSHIRE HOUSING

September 28, 2004

Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429

RE: RIN 3064-AC50

Dear Mr. Feldman:

I am concerned about proposed rule changes which would effect the application of the Community Reinvestment Act (CRA) to mid-sized bamls. CRA is vital for increasing homeownership and economic development in lower-income communities. However, your proposed changes will halt the progress that has been made.

I understand that banks with over $250 million in assets must be tested on their number of loans, investments, and services to low- and moderate-income communities. But your proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This could result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers, and economic development projects.

In the modified exam, you would allow mid-sized banks to choose which community development activities they will undertake. Right now, these banks must make community development loans, investments, and services. Your proposed test allows banks to choose only one of the three activities. The result may be less community development activity.

You also propose that community development activities in rural areas should benefit any group of individuals instead of only low- and moderate-income individuals. But this will allow banks to focus on affluent residents of rural areas rather than the lower income consumers CRA targets. Finally, you would also eliminate publicly available data on the small business lending of mid-sized banks. Without such data, community groups and citizens cannot hold banks accountable for lending to small businesses in their neighborhoods.

Your changes would undercut CRA's mandate to require lenders to meet community needs. Please consider your proposal to change the CRA requirements for smaller institutions.

Sincerely,
Claira P. Monier
Executive Director
New Hampshire Housing
Bedford, NY

Last Updated 10/18/2004 regs@fdic.gov

Last Updated: August 4, 2024