From: Rosemarie Monge
[mailto:rmonge@sjfund.com]
Sent: Monday, September 20, 2004 6:01 PM
To: Comments
Subject: RIN Number 3064-AC50
September 20, 2004
Mr. Robert E. Feldman
Executive Secretary
ATTN: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 E. 17th Street, NW
Washington, DC 20429
RE: RIN 3064-AC50
Dear Mr. Feldman,
I am a concerned citizen opposed to the watering down of the Community
Reinvestment Act (CRA) requirements for mid-sized banks. 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 will result in significantly fewer loans
and investments in affordable rental housing, health clinics, community
centers, and economic development projects.
In the watered-down 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 will 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 cherry-pick
and focus on affluent residents of rural areas rather than the lower
income consumers that the CRA currently targets. Finally, you would
eliminate publicly available data on the small business lending of
mid-sized banks. Without data, community groups and citizens cannot
hold banks accountable for lending to small businesses in their neighborhoods.
Your changes directly oppose CRA’s mandate to require lenders
to meet community needs. CRA is too important to be gutted. Please
drop your proposal, as the other two federal agencies that recognized
its harm to underserved communities have already done.
Sincerely,
Rosemarie Monge
Philadelphia, PA
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