From: Sandra Rosenblith [mailto:SRosenblith@liscnet.org]
Sent: Monday, September 13, 2004 3:35 PM
To: Comments
Subject: RIN 3064-AC50
Re: RIN 3064-AC50
Gentlemen:
I am a lawyer who helped draft the original CRA regulations adopted
unanimously by the FDIC and three other major federal financial
regulatory agencies. In 2002, I celebrated the 25th anniversary of
CRA
and the tremendous positive change it has produced, i.e., $1.5 trillion
in private capital invested to benefit low and moderate income people
and communities.
Having worked in community development for the nearly three decades
since, I've seen the real difference CRA makes in peoples' lives.
CRA has stimulated banks to help finance hundreds of thousands of
affordable homes and tens of thousands of small businesses, farms
and
facilities like supermarkets, shopping centers and industrial parks
as
well as childcare centers, medical clinics and churches. As a result,
whole city neighborhoods and small towns have revived and thrived.
CRA works. It is essential fuel for what President Bush calls the
Ownership Society. No banks have failed making CRA investments. In
fact, many have grown as the people and communities benefiting from
CRA
prospered.
I strongly oppose the proposed changes in the CRA regulations. They
aren't broke, and they don't need fixing. The proposed changes will
be especially hurtful to rural communities, even whole mainly rural
states. For example, if the proposed rule is adopted, Alaska, Arizona,
Idaho, Minnesota, Montana, New Mexico, West Virginia and Wyoming
won't
have a single FDIC regulated bank subject to full CRA examination.
34
other states will have five or fewer covered lenders.
Rural areas are poorer than metropolitan areas and they are served
by
fewer lenders. It is especially important to retain the requirement
that rural banks help meet the credit needs of low and moderate income
places and people. Access to bank financing is particularly important
to them because other capital is a very scarce commodity.
Respectfully,
Sandra Rosenblith
Chevy Chase, MD
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