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FDIC Federal Register Citations



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FDIC Federal Register Citations


From: Bethany Porter Sanchez [mailto:clubbethany@hotmail.com]
Sent: Thursday, September 16, 2004 5:58 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment

RE: RIN 3064-AC50, Community Reinvestment

Dear Mr. Feldman:

I am writing as a concerned citizen to express my strong opposition to the FDIC's proposal to significantly weaken the Community Reinvestment Act (CRA).

Having worked for nonprofits involved in housing and community development for over 25 years, and having worked with lenders trying to meet their CRA requirements, I believe that the FDIC's proposal will result in significantly fewer home loans and small business loans to low and moderate income borrowers, and significantly fewer community development loans and investments in low and moderate income communities.

The impact of the proposed CRA changes would be huge. Nationally, this proposed definition would would make 879 state-chartered banks with over $392 billion in assets eligible for a streamlined and cursory CRA exam. The impact on FDIC-regulated institutions in Wisconsin would be that an additional 27 Wisconsin institutions' CRA commitments would be reduced significantly. While this represents 12.5% of the FDIC-regulated institutions in the state, their $10.35 billion in assets represent 35.88% of the of Wisconsin's FDIC institutions.

Looking at just the urban areas, an additional 22 urban-based Wisconsin institutions' CRA commitments would be reduced significantly. This represents 24.4% of the urban FDIC-regulated institutions in the state and their $8.9 billion in assets represent 52.5% of the assets of Wisconsin's FDIC-regulated institutions. Again, these numbers represent the additional Wisconsin institutions and assets that would have significantly reduced CRA requirements under this proposal.

In addition, the proposal would allow banks to 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. This is directly contrary to CRA’s focus on meeting credit needs of low and moderate income communities.

In summary, these proposals will result in significantly fewer loans, investments, and branches in low and moderate income communities. Please withdraw this harmful proposal.

Sincerely,

Bethany Sanchez
2303 E. Belleview Place, #1
Milwaukee, WI 53211

Last Updated 09/22/2004 regs@fdic.gov

Last Updated: August 4, 2024