FDIC Federal Register Citations

SECRETARIAT FOR CATHOLIC HUMAN SERVICES
OFFICE FOR COMMUNITY DEVELOPMENT
ARCHDIOCESE OF PHILADELPHIA
222 North Seventeenth Street
Philadelphia, PA 19103-1299

September 20, 2004

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

Dear Mr. Curry:

I write to you on behalf of the Office for Community Development of the Archdiocese of Philadelphia, a 501(c)(3) community development corporation, to express my sincere concerns regarding proposed changes to Community Reinvestment Act exam thresholds. Setting a lower CRA standard for institutions with under $1 billion in assets by not considering their investments and services will weaken the CRA overall—and negatively impact community development efforts.

The Office for Community Development of the Archdiocese of Philadelphia has looked to the CRA as a significant part of the blueprint for establishing partnerships with banking institutions. These partnerships have been critical to our work in distressed neighborhoods throughout Philadelphia: transitional housing for homeless families; community center; vacant housing rehabilitation for low and moderate-income homeownership; senior housing; et al. The work of neighborhood revitalization and serving special needs communities remains quite challenging even with the current CRA standards. Please do not create new obstacles to this important work.

Please take this opportunity to reinforce the role of banking institutions in serving our communities by not changing the current CRA standards. Thank you.

Sincerely,

John M. Wagner
Director