FDIC Federal Register Citations

From: Maeve Elise Brown [mailto:mebrown@nhlp.org]
Sent: Tuesday, September 21, 2004 12:46 PM
To: Comments
Subject: Community Reinvestment. 12 CFR Part 345.

RE: FDIC Proposed Relaxation of CRA Oversight

Dear Sir or Madam:

The National Housing Law Project strongly opposes the FDIC's proposed relaxation of oversight, specifically its proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act (CRA). This policy would significantly reduce lending, investments and services in low-income communities.

The CRA has a lengthy history of making a positive impact on communities by creating incentives for banks to invest. Despite its dramatically positive impact, there are still communities, rural and urban, that are suffering from a lack of access to capital and institutional disinvestment. Government oversight of financial institutions is critical to the success of the CRA. The CRA needs to be strengthened and its protections extended rather than limiting its application to
institutions. I urge you not to allow banks with assets above $250 million to be examined as small banks under the CRA.

Sincerely,

Maeve Elise Brown, Esq.
Director Section 8 Homeownership &
Anti-Predatory Lending Initiatives
National Housing Law Project
(510) 251-9400, ext. 110