From: Kori Schneider [mailto:korischneider@mcleodusa.net]
Sent: Thursday, September 16, 2004 3:38 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-AC50, Community Reinvestment
Dear Mr. Feldman:
I live in a low-income neighborhood, and I am a staffperson from
a
nonprofit organization that works in housing and community development,
that's why I am writing to express my opposition to the weakening
of CRA
(Community Reinvestment Act) requirements for mid-sized banks. CRA
is vital
for increasing housing opportunity, homeownership and economic development
in lower-income communities. However, changes proposed by the FDIC
will
halt the progress that has been made.
I understand that currently, banks with over $250 million in assets
must be
tested on their number of loans, investments, and services to low
and
moderate income communities. But the proposal would eliminate the
investment and service requirements for all banks with under $1 billion
in
assets. This will result in significantly fewer loans and investments
in
affordable rental housing, health clinics, community centers, and
economic
development projects.
In the watered-down exam, the FDIC would allow mid-sized banks to
choose
which community development activities they will undertake. Right
now, these
banks must make community development loans, investments, and services.
The
proposed test allows banks to choose only one of the three activities.
The
result will be less community development activity.
I am also concerned about the proposal that community development
activities
in rural areas should benefit any group of individuals instead of
only low
and moderate income individuals. This would allow banks to work with
affluent residents of rural areas rather than the lower income consumers
CRA
targets.
Finally, the proposal would also eliminate publicly available data
on the
small business lending of mid-sized banks. Without data, community
groups
and citizens cannot hold banks accountable for lending to small businesses
in their neighborhoods.
The proposed changes directly oppose CRA's mandate to require lenders
to
meet community needs. CRA is too important to be gutted. Please drop
your
proposal. It would harm, rather than help underserved communities.
Sincerely,
Kori A. Schneider
3347 N. 50th Street
Milwaukee, WI 53216
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