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FDIC Federal Register Citations



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FDIC Federal Register Citations

From: williamskc@wi.rr.com [mailto:williamskc@wi.rr.com]
Sent: Thursday, September 16, 2004 3:36 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429

RE: RIN 3064-AC50, Community Reinvestment

Dear Mr. Feldman:

As a concerned citizen and a staffperson from a nonprofit organization that works in housing and community development, I am writing to express my opposition to watering down CRA (Community Reinvestment Act) requirements for mid-sized banks. CRA is vital for increasing housing opportunity, homeownership and economic development in lower-income communities. However, changes proposed by the FDIC will halt the progress that has been made.

I understand that currently, banks with over $250 million in assets must be tested on their number of loans, investments, and services to low and moderate income communities. But the proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers, and economic development projects.

In the watered-down exam, the FDIC would allow mid-sized banks to choose which community development activities they will undertake. Right now, these banks must make community development loans, investments, and services. The proposed test allows banks to choose only one of the three activities. The result will be less community development activity.

I am also concerned about the proposal that community development activities in rural areas should benefit any group of individuals instead of only low and moderate income individuals. This would allow banks to work with affluent residents of rural areas rather than the lower income consumers CRA targets.

Finally, the proposal would also eliminate publicly available data on the small business lending of mid-sized banks. Without data, community groups and citizens cannot hold banks accountable for lending to small businesses in their neighborhoods.

The proposed changes directly oppose CRA's mandate to require lenders to meet community needs. CRA is too important to be gutted. Please drop your proposal. It would harm, rather than help underserved communities.

Sincerely,
Kathleen C. Williams
3109 S. Pennsylvania Ave.
Milwaukee, WI 53207

Cc: National Community Reinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards

Last Updated 09/25/2004 regs@fdic.gov

Last Updated: August 4, 2024