FDIC Federal Register Citations

Progressive Redevelopment


To Federal Deposit Insurance Corporation

September 7, 2004

To Whom It May Concern:

I write as president of Progressive Redevelopment, the largest nonprofit developer of affordable housing in the state of Georgia, to strongly urge you not to eviscerate the CRA regulation by exempting banks with under $1 billion in assets from its requirements.

Community development as we know it can be divided into the “pre-CRA” and “post-CRA” eras. As a 15-year veteran of community development and affordable housing deals, I can attest that pre-CRA, it was an enormous struggle to get the attention of banks to make safe and sound loans. An entire industry has now evolved that is proficient in the cumbersome process of multi-layered financing. As bad as this system is, it works to some degree, by providing capital for housing for thousands of low-income families that need it and investment in low-income communities that otherwise would not have access to mainstream capital.

The CRA is arguably the most important legislation pertaining to community development and affordable housing that we have. Public subsidies are in scarce supply and appear to be diminishing. This would be the worst possible time to eliminate regulatory incentives to induce private capital to participate in community development activities.

With wages not keeping pace with rents in the lower quintile of incomes and with public subsidy programs under assault, the “least of these” will be forced to endure worst housing and worsening communities if this regulation is allowed to be gutted.

Thank you for this consideration. I would be pleased to provide more information if that would be of any help in your deliberations.

Bruce Gunter
President