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IRMAS HOUSING CONDITIONS PROJECT
From: Elissa Barrett
Sent: Tuesday, September 14, 2004 6:42 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
RIN 3064-AC50: OPPOSED TO PROPOSED CHANGES IN THE COMMUNITY
REINVESTMENT ACT
Bet Tzedek (House of Justice) Legal Services provides free legal
assistance to thousands of people who would otherwise be unable to
afford legal counsel for themselves.
Based on decades of representing low-income tenants in Los Angeles,
Bet Tzedek understands that targeted investment in residential housing
inside low income neighborhoods (either through in-fill projects or
rehabilitation) is crucial to alleviating California's housing crisis.
The Community Reinvestment Act is a critical component of our
community's affordable housing and community development solutions.
Targeted investment in the creation or rehabilitation of affordable
housing happens because lenders have strong incentives to participate.
Any change in FDIC regulations that reduces those incentives or reduces
the investment partners subject to those incentives cripples
California's ability to respond to its ever-broadening housing crisis.
Without such investment, the existing housing stock will continue to
decline (in quantity and quality), driving prices up and leaving
families who already pay more than 50% of their monthly income on rent
trapped in slum housing — with all the attendant risks to their
childrens' health and safety. See http://housingcrisisla.ucla.edu and
http://www.ucl.ac.uk/dpu-projects/Global_Report/pdfs/LA.pdf.
Without such investment, we all bear the costs of these health risks.
For instance, the Department of Housing and Urban Development estimates
that the U.S. economy has lost $1.54 billion, the economic benefit in
terms of lifetime earnings from children who would have been productive
members of society had they been protected from lead paint poisoning (a
health risk closely associated with slum housing).
Bet Tzedek therefore opposes any increase to the threshold of what is
considered to be a small bank. The proposed FDIC rule would exempt many
of our community's critical partners from the effective and productive
requirements currently in place. In sum, Bet Tzedek opposes RIN
3064-AC50 and joins the hundreds of other housing advocates in urging
the FDIC to withdraw its proposed rule.
Sincerely,
Elissa D. Barrett
Bet Tzedek Legal Services
Irmas Housing Conditions Project
145 S. Fairfax Ave., Ste. 200
Los Angeles, CA 90036
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