FDIC Federal Register Citations

From: Helen Lehman [mailto:westgdc@iserv.net]
Sent: Thursday, September 16, 2004 1:47 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

As the Executive Director of a small, neighborhood-based community development corporation, I am writing to express my outrage at the proposed changes to the CRA that would allow all banks with assets under $1 billion to have the limited CRA exam.

Organizations such as ours, which produce the majority of affordable housing units in this country, could not operate without the "hammer" that the CRA holds over lenders. Access to cash for rehabilitation and acquisition would not happen without the CRA requirements currently in place. I can name banks that would no longer be working with us, if this proposed change takes place.

The FDIC and OCC need to take a hard look at this proposal. It serves no one in the low and moderate income neighborhoods we serve. The gaps in affordability continue to widen. Let's not allow this change to make the gap even wider. The rehabilitation of our core cities depends on this leverage point.

Helen Lehman
Executive Director
New Development Corp.
fka West Grand Development Corp.
671 Davis, NW
Grand Rapids MI 49504
616/451-2291 (phone)