FDIC Federal Register Citations

From: Ray Neirinckx [mailto:rneirinckx@rihousing.com]
Sent: Thursday, September 16, 2004 1:00 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

My name is Ray Neirinckx. I am the coordinator for the Office of Community Development for the State of Rhode Island Housing Resources Commission*. I have been involved in CRA work since 1985.

I am opposed to the FDIC rule change to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act (CRA). This policy would reduce lending, investments and services in low-income communities.

Creating strategic alliances with financial institutions is critical to community asset building. CRA is an important tool to engage lenders in community economic development work in our neighborhoods. The proposed rule change could reduce the percentage of banks with full CRA exams to 6%. We need all banks to partners in our community development work. We are reaching out to expand the level of investment, lending and services being offered by our small bank in Rhode Island. The proposed rule change will be a set-back to expanding engagement by our small banks in Rhode Island and across the country. We urge the FDIC to reconfirm the important alliances to community reinvestment by rejecting the rule change on small banks.

Sincerely,
Ray Neirinckx
RIHRC
41 Eddy Street
Providence, RI 02903
401-450-1356

*for identification purposes only