FDIC Federal Register Citations

From: Chatfield7@aol.com [mailto:Chatfield7@aol.com]
Sent: Monday, September 13, 2004 11:48 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Thank you for the opportunity to submit comments on the proposed rule change. I am strongly opposed to the adoption of this proposed rule. The revision would significantly reduce the amount of CRA funds available for affordable housing production in the state of Arizona.

I have read the comments of a number of bankers who complain about "unnecessary regulation" and the "burden" on smaller banks. During nearly 20 years of urban planning work in the Southwest, I've seen the CRA provide significant stimulus to revitalize communities. We are often able to do so with funds from the smaller community banks because the big players divert their funds to larger population centers.

I believe in the power of the marketplace, but the banking industry has demonstrated that it needs this kind of oversight to ensure equal access to capital across the community. In areas of my community where the major banks have closed branches (leaving residents to check cashing services and payday loan sharks), the only real access to affordable capital is through CRA programs. And these are largely through small, local banks.

We've known that a proposal like this would come down the pike, because the banking industry has long complained about these requirements. But, in the name of fairness and community health, I implore you to reject this proposal.

Respectfully submitted,
Don Chatfield, Ph.D.
Tucson, Arizona