FDIC Federal Register Citations

From: kayzar [mailto:kayzar@cox.net]
Sent: Thursday, September 16, 2004 7:48 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I worked in banking and mortgage finance for many years and am now teaching and conducting research about urban issues. It has been my experience that the CRA works as an incentive for banks to invest in their local community. I fear that a 'relaxation' of the oversight for many banks with regard to the CRA will reduce this incentive. Drs. Ford and Griffin from San Diego State demonstrated the ill effects of redlining on inner-city communities in the San Diego and Columbus, Ohio area in their research during the 1970s and 1980s. Can we really afford to let banks 'choose to overlook' older or lower-income communities once again because they are no longer held to a higher standard by intensive CRA audits? Since it has been demonstrated as a problem in the past, I question the logic for this 'relaxation' of oversight. Is it simply because costs can be lowered if fewer banks are subject to the more intensive audit? I hope that this change will not come to pass-for the sake of the populations that benefit from such community reinvestment programs as those that target 'low-income homebuyers' as beneficiaries. Sincerely, Brenda Kayzar
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Brenda Kayzar
Department of Geography
San Diego State University