FDIC Federal Register Citations

From: cmckelway@penquiscap.org [mailto:cmckelway@penquiscap.org]
Sent: Wednesday, September 15, 2004 4:31 PM
To: Comments
Subject: CRA

To: Robert Feldman
Executive Seretary
Attn: Comments/Legal ISS
FDIC
550 17th Street NW
Washington, DC 20429--9990

Re: RIN 3064-AC50

To Whom It May Concern:

I manage a small rural Community Development Financial Institution in Maine. Prior to this I was a banker for 25 years. I see my current job as my opportunity to give back to my community by using the knowledge I developed as a banker. We provide one on one counseling to people who want to start a business, counseling to first time homebuyers, counseling to people who are possibly losing their homes in foreclosure, budget and debt management counseling to those who have taken on too much debt or been victims of predatory lending. Things that bankers understand are not common knowledge for many, especially low income people. I have been working for the past 3 years to build a performing loan portfolio with sufficient interest income to support our counseling and reduce our reliance on grant funding. I have raised loan funding for my programs to a large extent from banks who are working to comply with CRA. The CRA incentive really does encourage banks to address community needs and assist businesses like this one. I am not convinced that banks would have provided me with my financing without a CRA benefit to them. Having been a small rural bank CEO I understand the impact of this regulation on a small bank. I do not believe the burden on small banks is such that the program needs to be altered in a way that would negatively impact its community development benefits. I am therefore, opposed to the proposed rule changing the CRA. I believe it will have a negative impact on communities that need it most. I think you need to find a way to apply the CRA rules to credit unions. Why not focus your efforts on that sort of legislation?

Cathy McKelway