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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

HABITAT FOR HUMANITY, SOUTHEAST

September 3, 2004

Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ISS - FDIC
550 17th Street NW
Washington, DC 20429-9990

RE: RIN 3064-AC50

Dear Mr. Feldman,

During the 20 years I have worked in community services, I have encouraged non-profit organizations to partner with banks to make the CRA work for both of them. In particular, banks have collaborated with Habitat for Humanity affiliates in Alabama by providing office space, making no-interest loans, funding homes, teaching budgeting classes, and partnering in other innovative ways.

I oppose the proposed changes, which among other things will exempt banks with assets of between $250 million to $500 million from the lending and services provisions. I believe that the proposed changes will only continue to diminish the effectiveness of the CRA in our communities. Based on the Lending Test, the fifth criteria offers the community an expectation that the bank will be diligent in working collaboratively within the community, finding innovative and flexible lending practices to serve low-moderate income individuals and businesses. The statement "to reflect economic change and to reduce unwarranted burden" seems to me an intentional method of excluding low-moderate families from financial services.

After reviewing the number of banks in Alabama that are currently held accountable for their adherence to the CRA, and subtracting the number of banks that the exemptions will affect, I find that only nine banks in Alabama will be obligated to meet the full requirement of the CRA! Add to that a new definition for community development- “Activity (that) could benefit either low- and moderate-income individuals or individuals who reside in rural areas"- and we have a vague and hollow Community Reinvestment Act. How will bank’s “reinvestment” appear, if they are released from the obligation to provide services to low-moderate income families?

Sincerely,

Lisa Yee, ASM- SE Regional Support Center
Habitat Southeast
4525 Fairlane Court
Montgomery, AL 36106
 

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

Last Updated: August 4, 2024