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NEIGHBORHOOD HOUSING SERVICES OF MILWAUKEE, INC. From: Sallie Alefsen [mailto:salliea@nhsmilwaukee.org]
Sent: Thursday, September 16, 2004 2:36 PM
To: Comments
Subject:
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 member of the board of directors of the
Metropolitan Milwaukee Fairy Housing Council, 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,
Sallie Alefsen
Executive Director
Neighborhood Housing Services of Milwaukee, Inc.
535 North 27th Street
Milwaukee, WI 53208
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