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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations


GEORGIA STATE TRADE ASSOCIATION OF NONPROFIT DEVELOPERS

August 24, 2004

Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

John M. Reich
Vice Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Thomas J. Curry
Director
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

John D. Hawke, Jr.
Comptroller of the Currency
Office of the Comptroller of the Currency
250 E Street, SW
Washington, DC 20219

Gentlemen:

Our nonprofit developers, with the help of their governmental and philanthropic partners, use initiatives such as the Community Reinvestment Act to rebuild low-and moderate-income communities. They now face a serious challenge from the OTS and the FDIC as the developers continue their work of building additional housing for workforce and special needs populations.

Despite our successes locally and nationally, the banks and thrift institutions that provided the loans and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if you change the CRA exam threshold.

We hear that the Federal Deposit Insurance Corporation is considering changes to weaken the Community Reinvestment Act.

It is estimated that 2,000 financial institutions would no longer be evaluated on their investment or services to low- and moderate-income communities. These banks have assets of nearly $1 trillion, and an estimated $5 billion of private capital for affordable housing and community development may be lost over the next few years

These proposed rule changes would have a devastating effect on affordable housing investment in here in Georgia, and elsewhere throughout the nation, particularly in rural areas.

In a recent survey of members of the Georgia State Trade Association of Nonprofit Developers, 24 nonprofits created 4,218 units of new affordable housing and rehabbed 9,206 units. They used many layers of financing, and their financial partners were critical in providing mortgages, acting as sponsors for the FHLB's AHP and CIP programs, and purchasing tax credits.

Our concern is that this level of support will no longer be available, especially for small towns and rural communities in Georgia, if the CRA threshold amount goes to $1. billion.

The FDIC, and OTS, should be strengthening incentives for financial institutions to invest in the communities that provide homes, jobs, and economic opportunities to working families.

Please do not raise the CRA exam threshold.

Sincerely,

Kenneth J. Knox
Executive Director


Last Updated 09/14/2004 regs@fdic.gov

Last Updated: August 4, 2024