FDIC Federal Register Citations

ISHMON & ASSOCIATES, INC.
5950 Hohman Avenue
Hammond, Indiana 46320
(219) 931-0605
(219) 933-0499

September 16, 2004

Dear Mr. Feldman:

I am a concerned business owner strongly opposed to your proposal to significantly weaken the Community Reinvestment Act (CRA). You propose much easier CRA requirements for banks between $250 million to $1 billion in assets. This proposal will result in much fewer home and small business leans to low and moderate income borrowers and much few community development loans and investments in low and moderate income communities. In addition, you propose that all FDIC supervised banks can earn CRA points by financing community development projects that benefit affluent residents in rural areas, instead of low and moderate income consumers and communities in rural America. This is directly contrary to CRA’s focus on meeting credit needs of low and moderate income communities.

In summary, your proposal to change the CRA regulation will result in much fewer loans, investments, and branches in low and moderate income communities. Please withdraw your proposal to disenfranchise low income communities; if the banks could have been trusted we would have had no need for CRA. We need your help and consumers, tax payers, and citizens or this country. I trust that we can depend on you to consider our position.

Sincerely,
Jean Ishmon, President