FDIC Federal Register Citations

From: Rich Lee [mailto:rich@dahc.org]
Sent: Saturday, September 18, 2004 3:16 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment

September 18, 2004

Dear Mr. Feldman:

As Executive Director of the Durham Affordable Housing Coalition (DAHC), I am writing to express my strong opposition to your proposal to significantly weaken the Community Reinvestment Act (CRA). Given the growing shortage of affordable housing for low- and moderate-income households across the country and rising profits in the banking industry, the FDIC should be strengthening rather than weakening CRA requirements for banks.

You propose to relax CRA requirements for banks with assets between $ 250 million to $1 billion. This will result in fewer home and small business loans to low- and moderate-income borrowers as well as much fewer community development loans and investments in low- and moderate-income communities. In addition, your proposal that all FDIC-supervised banks can earn CRA points by financing community development projects that benefit affluent residents in rural areas, instead of low- and moderate-income consumers and communities in rural America, is directly contrary to CRA’s focus on meeting the credit needs of low- and moderate-income communities. As a result, your proposed changes to CRA regulations will result in significantly fewer loans, investments, and branches in low- and moderate-income communities. Please withdraw your harmful proposal.

Sincerely yours,
Richard Y. Lee
Durham Affordable Housing Coalition
331 W. Main Street
Durham, North Carolina