Habitat for Humanity of Tuscaloosa
September 16, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ISS - FDIC
550 17th Street NW
Washington, DC 20429-9990
RE: RIN 3064-AC50
Dear Mr. Feldman,
Habitat for Humanity builds simple, decent houses for low-income
families living in inadequate, substandard housing. The success of
the Habitat for Humanity program depends heavily upon its partnership
with banks to make the CRA work for both of them. In particular,
banks have partnered with Habitat for Humanity affiliates in Alabama
by providing office space, making no-interest loans, funding homes,
teaching budgeting classes, and partnering in other innovative ways.
Our affiliate, in particular, relies on the no-interest loan program.
This letter is to oppose the proposed changes, which among other
things will exempt banks with assets of between $250 million to
$500 million from the lending
and services provisions. The proposed changes will only continue to diminish
the effectiveness of the CRA in our communities. Based on the Lending Test,
the fifth criteria offers the community an expectation that the bank will be
diligent in working collaboratively within the community, finding innovative
and flexible lending practices to serve low-moderate income individuals and
businesses. The statement "to reflect economic change and to reduce unwarranted
burden" seems to me an intentional method of excluding low-moderate families
from financial services.
After reviewing
the number of banks in Alabama that are currently held accountable
for their
adherence to the CRA, and subtracting
the number of banks that the exemptions will affect, I find that
very few banks in Alabama will be obligated to meet the full requirement
of the CRA! Add to that a new definition for community development- “Activity
(that) could benefit either low- and moderate-income individuals
or individuals who reside in rural areas"- and we have a vague
and hollow Community Reinvestment Act. How will bank’s “reinvestment” appear,
if they are released from the obligation to provide services to low-moderate
income families?
Please help Habitat
for Humanity and other such programs continue to provide housing
to
our neighbors in need by leaving the CRA unchanged.
Help us continue this critical work of eliminating substandard housing
and making America’s communities better places to live!
Sincerely,
Lynne Morris
Executive Director
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