FDIC Federal Register Citations

From: Scott W. Gehl [mailto:sgehl@homeny.org]
Sent: Thursday, September 16, 2004 4:38 PM
To: Comments
Subject: RIN 3064-AC50

Dear Mr. Feldman:

Housing Opportunities Made Equal is a civil rights organization which, since 1963, has led the struggle for fair housing in Western New York.

As the executive director of HOME, I must respectfully oppose the FDIC’s proposed weakening of the Community Reinvestment Act (CRA). The FDIC’s proposal would lessen CRA requirements for banks between $250 million to $1 billion in assets. This proposal will result in much fewer home and small business loans to low- and moderate-income borrowers and much fewer community development loans and investments in low- and moderate-income communities.

In addition, you propose that all FDIC-supervised banks can 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 sum, your proposal to change the CRA regulation will result in much fewer loans, investments, and branches in low- and moderate-income communities.

We respectfully request that you withdraw this injurious proposal.

Sincerely,

Scott W. Gehl, Executive Director
Housing Opportunities Made Equal, Inc.
700 Main St/ Buffalo, NY/ 14202
(716) 854-1400 FAX: (716) 854-1140

HOME is a civil rights organization which, since 1963, has led the struggle for fair housing in Western New York. Membership information is available on the web at www.homeny.org.