From: Capps,
Randy [mailto:RCapps@ui.urban.org]
Sent: Monday, September 13, 2004 4:08 PM
To: Comments
Subject: Community Reinvestment - RIN 3064-AC50
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am a concerned citizen opposed to watering down CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA is vital
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.
Your changes directly oppose CRA's mandate to require lenders to
meet
community needs. CRA is too important to be gutted. Please drop your
proposal like the two other federal agencies that recognized its
harm to
underserved communities.
Sincerely,
Randy Capps
Cabin John MD 20818
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