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FDIC Federal Register Citations

EASTERN DAKOTA HOUSING ALLIANCE

From: Lisa Rotvold [mailto:edha@rrv.net]
Sent: Tuesday, September 07, 2004 11:22 AM
To: Comments
Subject: "RIN 3064-AC50"

Robert E. Feldman
Executive Secretary

Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429-9990.

Re: RIN 3064-AC50

I am writing to comment on the proposal to increase the floor for serious CRA exams for banks. I live in North Dakota and work in the field of affordable housing development. We frequently rely on our local banks for loans to make our affordable housing projects work. They can be complex projects and are not always the most appealing opportunities for these banks. But because of their CRA requirements they have done our deals and have helped create much needed affordable housing. It is critical that we have this tool in ND to keep the banks at the table with the affordable housing developers. They are good people but very conservative and are very likely to back off of financing deals like ours without the requirements of CRA in place.

ND is not the only state to be negatively affected by this proposed change. According to data from the Senate Banking Committee nine states would be left with no banks subject to CRA. Another 8 states would have only one bank subject to the act. Over all 24 states would have 2 or less banks subject to the act. The CRA has been such an effective tool in bringing the financing sector to the affordable housing table. They have made a real difference in the lives of so many low and moderate income Americans. I fear that this change will really slow down production of affordable housing at a time when more and more families are living in poverty. I ask that you please leave the floor for the serious CRA exams at the current level to enable us and other producers of affordable housing around the country to continue to rely on our local banks to help us make it happen.

Lisa Rotvold
Director
Eastern Dakota Housing Alliance
PO Box 758
Hillsboro, ND 58045

Phone: 701-636-5860
Fax: 815-642-0846

"Fostering the Development and Preservation of Affordable Housing in Eastern North Dakota."

Last Updated 09/08/2004 regs@fdic.gov

Last Updated: August 4, 2024