FDIC Federal Register Citations

From: by way of Marty Newell <cra@ruralstrategies.org> [mailto:hcgceopmc@mac.com]
Sent: Wednesday, September 15, 2004 4:39 PM
To: Comments
Subject: RE: RIN 3064-AC50

name: Herbert Chao Gunther
address: 1217 Clay Street
city_st: SF CA
zipcode: 94108

I strongly oppose the proposed rule changes in the Community Reinvestment Act (RIN 3064-AC50). This action will harm to rural communities. : Re: Community Reinvestment Act rule-making (RIN 3064-AC50)...

Exempting banks with $1 billion or less in assets from the same
community reinvestment criteria as larger banks is totally without justification and unwarranted. Social responsibility -- the fundamental obligations corporations have to the communities that provide their base capital -- isn't a function of
asset size and shouldn't be diminished by how large or small a bank is. Because rural America is underserved by banks and for most rural areas there is no effective competition, exempting
banks with $250 million to $1 billion will have the same effect as redlining as entire communities lose access to market-interest capital. A further devastating impact will be the expansion of high-margin
commercial lenders in rural areas as small banks cut back on CRA programs related to lending, investment and financial literacy.
FDIC should be doing more to expand capital access and financial services to under-served communities through the CRA, not doing less. Rural voters are paying close attention to this.
If FIDC withdraws from rural America, rural voters will have one more reason to elect new national leadership in November.