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FDIC Federal Register Citations


From: Janet Harry [mailto:janetaer@nls.net]
Sent: Thursday, September 02, 2004 11:23 AM
To: Comments
Cc: cford@ncrc.org; nmelton@ncrc.org
Subject: RIN 3064-AC50

Dear Mr. Feldman:

I am a concerned citizen opposed to decreasing CRA (Community Reinvestment Act) requirements for mid-sized banks. CRA is a vital ingredient in the struggle to increase homeownership and economic development in lower-income communities. Your proposal will halt the progress that has been made.

Currently, banks with over $250 million in assets must be tested on the number of loans, investments and services to low and moderate income communities. Your proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will ultimately result in fewer loans and investments in affordable rental housing, health clinics, community centers and economic development projects in areas that are severely depressed.

The adulterated exam would allow mid-sized banks to choose which community development activities they will undertake. Right now, these banks must make community development loans, investments and services. Your proposed test allows banks to choose only one of the three activities. The result will be decreased community development activity and increased asset loss to the community.

The proposal would also allow community development activities in rural areas that benefit any group of individuals, instead of targeting low-moderate income families, to qualify. This will allow banks to cherry-pick and focus on affluent residents in rural areas rather than the lower income consumers CRA was designed for. The proposal would also eliminate publicly available data on small business lending of mid-sized banks. Without data, community groups and citizens cannot hold banks accountable for lending to small businesses in their neighborhoods.

The proposed changes directly oppose CRA's mandate to require lenders to meet community needs. CRA is too important to the communities to allow it to be gutted. Please withdraw the proposal and thereby eliminate the harm that would result to underserved communities.

Sincerely,

Jan Harry
70 East Columbia Street
Alliance, OH 44601
PH: 330-829-9104
Fax: 330-829-0247
E-mail: janetaer@nls.net

CC: National Community Resinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards
 

Last Updated 09/03/2004 regs@fdic.gov

Last Updated: August 4, 2024