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FDIC Federal Register Citations

ALLIANCE FOR HEALTHY HOMES

From: Don Ryan [mailto:DRyan@AFHH.org]
Sent: Wednesday, September 15, 2004 5:15 PM
To: Comments
Subject: RE: RIN 3064-AC50

September 20, 2004

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

RE: RIN 3064-AC50

Dear Mr. Feldman:

On behalf of the Alliance for Healthy Homes, a national non-profit organization working to address environmental health hazards in housing, I am writing in opposition to the Federal Deposit Insurance Corporation’s August 20, 2004, proposed rule that would exempt some 96% of all FDIC-regulated banks from many of the requirements of the Community Reinvestment Act (CRA).

CRA has helped leverage billions of dollars in resources for decent and affordable housing over the past two and a half decades. In many cases, funding leveraged using CRA has improved the physical condition and affordability of homes, making the living environment more healthful for lower income occupants.

Housing conditions are an important factor in the health of occupants. Indoor exposures far exceed outdoor levels for most pollutants - often by a factor of at least 10 for many pollutants of concern. Moreover, most people spend about 90% of their time indoors. Infants and toddlers, whose developing bodies and brains make them most sensitive to pollutants, spend the most time at home. Older people, who are very sensitive to environmental toxins, also tend to stay at home more than most other age groups.

Each year in the U.S., two million people make emergency room visits for asthma. Damp, cold, and moldy housing is associated with asthma and other chronic respiratory problems. Pest infestations are also associated with asthma. In particular, cockroaches have been found to trigger asthma attacks. Lead poisoning affects some 434,000 U.S. children. Lead-based paint in older housing is the primary cause of the disease, which results in reduced intelligence and learning and behavior problems. Exposures to asbestos particles, radon gas, and carbon monoxide are far higher indoors than outside. Annually, radon causes between 15,000 and 22,000 deaths annually in the U.S., according to the U.S. EPA and the National Academy of Sciences, and carbon monoxide claims more than 200 lives.

While homes of any age and value can pose serious environmental hazards, older, low-income properties in substandard condition typically present the greatest risks. According to the U.S. Centers for Disease Control and Prevention, there are currently 6 million homes classified as substandard.

In some places (New Jersey, Massachusetts, and Long Beach, CA, are ready examples), CRA has been used to convince banks to create discounted financing programs specifically for lead paint other health-related repairs.

The FDIC’s proposed new rule would relieving some 2,000 banks - with total assets of more than $754 billion and branches in more than 18,800 communities - of their obligation to provide investments and services in low-income areas. This will undermine the ability of advocates for healthy homes to convince these banks to address these and other issues of housing condition and affordability. We strongly urge FDIC to withdraw its proposed rule in the interest of promoting a more healthful housing stock in low-income communities.

Sincerely,

Don Ryan
Executive Director
Alliance for Healthy Homes
227 Massachusetts Ave. NE #200
Washington, DC 20002
Phone: 202-543-1147
Fax: 202-543-4466
dryan@afhh.org
www.afhh.org

Founded in 1990 as the Alliance To End Childhood Lead Poisoning, we have expanded our work on lead poisoning prevention to address other housing-related health hazards.

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

Last Updated: August 4, 2024