FDIC Federal Register Citations

Business & Economic Development & Revitalization Corporation
of Palm Beach County

From: Gainesbedr@aol.com [mailto:Gainesbedr@aol.com]
Sent: Friday, September 17, 2004 12:54 PM
To: Comments
Subject: RIN 3064-AC50

Mr. Robert Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation

Dear Mr. Feldman:

As a "CED" (Community Economic Development) practitioner, I urge you to withdraw your proposed changes to the Community Reinvestment Act regulations. CRA is the incentive tool for increasing homeownership and stimulating economic development in Urban and Rural historically underserved areas. As a critical and rare investment tool, banks should not be released based upon size of assets to invest and serve low and moderate-income communities.

In addition eliminating any one of the three activities - community development lending, investing, and services - will result in even fewer loans and investments in affordable housing, community health centers, community centers and economic development projects in lagging regions.

The elimination of the service test would deal a "death blow" to responding to the credit needs of low and moderate income consumers and small businesses because of the lack of data collection which would result from no longer provide affordable checking and savings accounts to low income consumers and lending to small businesses. Without this data the public has no accountability tool for gauging whether the credit needs of these communities are being served. Your proposal that community development activities benefit any group of individuals rather than only low and moderate income individuals will result in a sharecropping system of predatory and trickle down community development activities in these communities. Activities must be targeted to those in greatest need. Otherwise benefits will be channeled to those with greater influence and access and activities will benefit those who have over those who do not.

Finally, your proposal is in direct contravention to the mandate of the CRA to meet community needs. Please consider this request to withdraw your proposal. Let us jointly (banking and ced community) develop a path that would expand and not eliminate the tools for equitable and prosperous community and economic development for historically underserved persons and communities.

Sincerely,

Lia T. Gaines
President and CEO
Business & Economic Development & Revitalization Corporation of Palm Beach County