FDIC Federal Register Citations

W.O.R.K.S.

From: Channa Grace
Sent: Friday, August 20, 2004 5:59 PM
To: Comments
Subject: Please withdraw the proposed rule to raise the small bank asset threshold

To Whom It May Concern,

I represent a smaill non-profit affordable housing development firm and the Community Reinvestment Act is critical to the work we and others like us throughout this nation undertake on behalf of persons with modest means. Raising the asset threshold for “small banks,” which are exempt from the Community Reinvestment Act’s more stringent exams, will undoubtedly jeopardize the work that we do by significantly reducing investments in low and moderate income communities Such a change will mean that many rural communities and states will not have access to any institutions required to offer services and investments that benefit low and moderate income neighborhoods.

Presently, those banks subject to the CRA must demonstrate that they provide both services and investments that benefit low and moderate income households and neighborhoods in their communities. The Community Reinvestment Act is a critical component to the work we do and our community’s affordable housing and community development solutions. We oppose any increase to the threshold of what is considered to be a small bank. The proposed FDIC rule would exempt many of our community’s critical partners from the effective and productive requirements currently in place. We urge FDIC to withdraw its proposed rule.


Sincerely,

Channa Grace
W.O.R.K.S.
1139 West 6th Street
Los Angeles, CA 90017