FDIC Federal Register Citations

From: John Norwood [mailto:jmnorwood@hotmail.com]
Sent: Friday, September 17, 2004 12:36 PM
To: Comments
Cc: sharon@desmoinescci.org
Subject: 3064-AC50

Dear Mr. Feldman:
As a member of a community investment advocacy group, I am writing to express my opposition to the proposed amendments to the Community Reinvestment Act (CRA). Here in Des Moines, Iowa, it has taken over a decade of hard work to get our local banks to focus on the importance of providing non-predatory financing to our credit and capital starved inner cities.
CRA has been the stick that has allow this work to begin. Now, banks are beginning to realize that servicing low and moderate income areas can be profitable -- and that's the carrot. Still, now is not the time don't to weaken CRA. We need to strengthen it by setting even more bold goals and holding institutions accountable.

For example, we need better performance measurement capabilities through CRA reporting requirements which can enable to local independent advocacy groups, like CCI, work with lenders to understand how many loans and dollars are flowing into our needy neighborhoods, strengthening home ownership and local business development. Better reporting and disaggregration of data through HUMDA will assist in this process. More timely reporting of bank examinations will also allow earlier course corrections. Two and three year time lags are unacceptable.
In closing, CRA doesn't need to be weakened. It needs to be strengthened and refined. The hardwork is just beginning to pay off. Now is not the time to loosen the reigns. We need your leadership to continue the strengthening of our core inner cities across this great nation.

Sincerely,
John Norwood

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John Norwood
1611 Green Branch Circle
West Des Moines, IA