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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations


ATLANTA NEIGHBORHOOD DEVELOPMENT PARTNERSHIP


August 30, 2004

Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

John M. Reich
Vice Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Thomas J. Curry
Director
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

John D. Hawke, Jr.
Comptroller of the Currency
Office of the Comptroller of the Currency
250 E Street, SW
Washington, DC 20219

Re: Community Reinvestment Act

Dear. Sirs:

The Community Reinvestment Act (CRA) of 1977 has been, the largest-contributor over time other than the Low Income Housing Tax Credit, to the revitalization of America's cities and rural areas. In the world of changing economics and reduced Federal funding things that require investments in our lowest income neighborhoods are even more necessary than before. The progress that has been made in improving our communities could not have been possible without the banks and thrift institutions that provided loans and investments to build new homes, businesses and community facilities.

The idea of raising the CRA exam threshold will erase the need for small banks (under $1 billion in assets) to invest in all of the communities that they receive deposits from. Experience shows us that lending institutions need incentives to make loans arnd investments inunderserved areas.These areas became underservedwhen there were no incentives such as CRA. The proposed change will have a devastating effect on affordable housing investment in our state and throughout the nation particularly in rural areas. This comes at a time when the number two concern for most Americans affordable housing behind health care.

The Atlanta Neighborhood Development Partnership has been In business since 1991 and has either built or invested in over 7,500 units of affordable housing. Financial Institutions have been an integral part of this work. We believe that the regulating authorities should be strengthening incentives for financial institutions to invest in communities that have been overlooked in the past. Please do not raise the CRA exam threshold.

Sincerely
Raymond L. Kuniansky, Jr.
Chief Operating Officer


 

Last Updated 09/13/2004 regs@fdic.gov

Last Updated: August 4, 2024