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FDIC Federal Register Citations

CENTER FOR ECONOMIC PROGRESS

From: Steven Neumann [mailto:SNeumann@centerforprogress.org]
Sent: Wednesday, September 15, 2004 12:43 PM
To: Comments
Subject: Withdraw Proposed Changes to CRA regulations

Please forward this message to:

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

RE: RIN 3064-AC50

Dear Mr. Feldman:

I would like to strongly urge you to withdraw the current proposed changes to CRA (Community Reinvestment Act) requirements for mid-sized banks. CRA is vital for increasing homeownership and economic development in lower-income communities. However, your proposed changes will halt the progress that has been made.

I understand that banks with over $250 million in assets must be tested on their number of loans, investments, and services to low- and moderate-income communities. But your proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers, and economic development projects.

After the proposed changes, mid-sized banks would be allowed 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 less community development activity.

You also propose that community development activities in rural areas should benefit any group of individuals instead of only low- and moderate-income individuals. This runs contrary to the fundamental intent of CRA requirements - to ensure greater access to needed financial services among chronically underserved consumers. Finally, you would also eliminate publicly available data on the 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. This data is absolutely crucial.

Your changes directly oppose CRA’s mandate to require lenders to meet community needs. CRA is too important to be gutted. Please drop your proposal like the two other federal agencies that recognized its harm to underserved communities.

Sincerely,

Steve Neumann
Financial Education Associate
Americorps VISTA Volunteer
Center for Economic Progress
29 E. Madison Street, Suite 910
Chicago, Illinois 60602

Last Updated 09/17/2004 regs@fdic.gov

Last Updated: August 4, 2024