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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

Southern Mutual Financial Services

From: Southern Mutual Financial Services [mailto:smfs@southernmutualhelp.org]
Sent: Monday, October 04, 2004 12:40 PM
To: Comments
Subject: Comments on CRA

September 28th, 2004

Dear FDIC Commissioners,

We are writing against the proposed changes to rules governing the Community Reinvestment Act (CRA). In particular, we are opposed to changing the definition of a "small bank" from a bank with assets of 250 million dollars to a bank having assets of one billion dollars. The proposed changes would adversely impact our work with poor families in rural areas by removing incentives for local, community banks to invest in the future prosperity and health of the communities that they serve. Under the proposed change, there will be only four banks in Louisiana with more than one billion dollars in assets.

Our bank partners have told us that without CRA, they would not have invested in our work, our families, or our rural communities. Under the proposed changes, only one bank partner will receive the full CRA exam; only one bank will have incentives to invest in our work in poor rural communities. CRA regulations are not only better for communities, but better for banks–providing banks with the flexibility and incentive to develop new markets over the long term.

Without the current CRA regulations, the responsibility for community investment will be transferred to already overburdened local and state governments, who may be unable to meet the needs of so many under served families and communities. We urge you to maintain the current "small bank" definition so that local, smaller banks are provided with continued incentive to invest in their communities.

Sincerely,

Lorna Bourg
Treasurer, Southern Mutual Financial Services

 

Last Updated 10/08/2004 regs@fdic.gov

Last Updated: August 4, 2024