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FDIC Federal Register Citations
Lancaster Housing Opportunity Partnership
From: Dan Basehoar [mailto:dbasehoar@lancasterhousing.org]
Sent: Monday, September 20, 2004 11:13 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
To whom it may concern:
This is to advise that the Lancaster Housing Opportunity Partnership
(LHOP) strongly opposes the proposal by the Federal Deposit Insurance
Corporation (FDIC) to allow banks with assets above $250,000 million
to be examined as small banks under the Community Reinvestment Act (CRA).
We similarly oppose any similar effort by the other government regulatory
bodies like Office of Thrift Supervision (OTS), the Federal Reserve Board,
and the Office of the Comptroller of the Currency.
LHOP was incorporated in 1995 to promote expansion of affordable housing
opportunities for both renters and first time buyers in Lancaster City
and County, Pennsylvania. In that capacity, in 9 years, we have worked
with area banks and mortgage companies to help 1200 new homebuyers and
develop more than 300 additional affordable housing units.
We have found the current CRA requirements to be a strong ally in our
efforts to develop collaborative lending and investment programs working
with local banks. We find that, with all the mergers/acquisitions of
the “super regional” banks, the focus of larger banks now
seems to be on the larger urban markets of Philadelphia and Pittsburgh,
not the smaller markets of central Pennsylvania.
As a result, smaller local “home town” banks, often with
assets under the $1 billion limit proposed, now need to play a much larger
role as our local partners. We are very concerned that the rule change
proposed will eliminate current incentives to their participation in
local housing and community development programs.
In consideration, we strongly urge FDIC and other regulating bodies not
to reduce the current thresholds.
Daniel E. Basehoar
Lancaster Housing Opportunity Partnership
30 West Orange Street, Suite 150
Lancaster, PA
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