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FDIC Federal Register Citations

Utica/Central New York Citizens in Action

From: Cnycitizenaction@aol.com [mailto:Cnycitizenaction@aol.com]
Sent: Friday, September 17, 2004 1:15 PM
To: comments@FDIC.gov.
Subject: RIN 3064-AC50

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
RE: RIN 3064-AC50

Dear Mr. Feldman:

I am the President of the Utica/Central New York Citizens in Action. We are writing to voice our opposition to watering down CRA (Community Reinvestment Act) requirements for mid-sized banks. CRA has been a successful tool 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 CRA targets. Finally, you would also 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.

The City of Utica is located in Upstate NY between Albany and Syracuse. We have lost one-third of our population since 1970 and have rates of poverty. Much of our housing stock has been demolished. However, we have significant opportunities at this time to transform our community into a model for sustainable urban redevelopment. The CRA is essential to our community redevelopment efforts.

The Utica Citizens in Action is a multi-issue advocacy organization concerned with neighborhood redevelopment, predatory lending, affordable housing, and community-based economic development. We have over 500 members.

Located In Utica, New York, our community-based and multicultural organization is committed to living wage jobs, affordable health care and education, educational opportunities, and improvement in living conditions for low and moderate income people. We are a membership organization which consists of working people, tenants, small business persons, the elderly, students, clergy, and representatives of the labor movement. Our organization is a community-labor-faith-based coalition dedicated to revitalizing Utica's distressed neighborhoods. We also advocate for low-income and marginalized neighborhoods in the Central New York region. Our group is affiliated with Citizen Action of New York, a large multi-issue membership organization consisting of over 20,000 members.

Established in 1997, our organization has been successful in highlighting public attention on local economic development issues, health maintenance organization reform, affordable housing, and consumer rights. We have successfully conducted campaigns on neighborhood development, media accountability, and health care and joined state and national organizations in advocating for progressive policies.

We are respectfully requesting that you withdraw your proposal to gut the CRA. Thank you for considering our comments.

Sincerely,

John Furman
President
Utica Citizens in Action
P.O. Box 411
Utica, New York

 

Last Updated 09/28/2004 regs@fdic.gov

Last Updated: August 4, 2024