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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations


OREGON HOUSING AND COMMUNITY SERVICES

September 10, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: CommentslLegal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington DC 20429

RE: RIN No. 3064-AC50

Dear Mr. Feldman:

Oregon Housing & Community Services (OHCS) urges you to withdraw your proposed changes to the Community Reinvestment Act (CRA) regulation. We believe the proposed change will undermine the intent of the law to provide equitable lending in underserved communities.

The proposed changes will eliminate the investment and service parts of the CRA exam for state-chartered banks with assets between $250 million and $1 billion. In place of the investment and service parts of the CRA exam, the FDIC proposes to add a community development criterion. The community development criterion would require banks to offer community development loans, investments or services. The community development criterion would be seriously deficient as a replacement for the investment and service tests.

While OHCS believes that updating and simplification of the program is warranted, we are concerned that the proposed change could allow more than a thousand banks to back away from their community development obligations, causing funding for affordable housing to be diminished or, in some communities, eliminated altogether.

The Community Reinvestment Act is perhaps one of the most successful community revitalization programs in the nation's history. Oregon has taken unique approaches to make development of low income housing a priority, such as the creation of the Farmworker Housing Tax Credit. The benefits of this state tax credit to local communities and to our agricultural economy, combined with the benefit to banks in meeting CRA goals, has made this a successful program to fund farmworker housing in Oregon. Many of the credits have been purchased by banks that would have diminished CRA obligations under the proposed change.

We urge you to:

  • Maintain an investment test as part of banks' CRA performance by maintaining the "small bank" definition at the $250 million asset threshold.
  • Continue to hold banks that are part of large holding companies to the "large institution" standards.
  • Expand CRA so that it better reflects changes in the financial services industry brought about by market shifts, technology advances, and financial modernization legislation.

Sincerely,
Jack Kenny
Deputy Director
Oregon Housing & Community Services

Last Updated 09/14/2004 regs@fdic.gov

Last Updated: August 4, 2024