FDIC Federal Register Citations

Henry K. Holsman Institute for Advanced Affordable Family Housing Studies

From: J. Peter Holsman [mailto:j.peter.holsman@comcast.net]
Sent: Monday, October 04, 2004 2:32 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I am a third generation affordable housing and remodeling design-build architect –builder of 42 years (64 years old) and I think the proposed changes in the CRA are COMPLETELY BACKWARDS !

It is the smaller institutions that should get more of a “push” from the system since they are closest to the local neighborhoods where the best community redevelopment and more human and family-oriented affordable working and living environments are financed and thus actually built.

Thus the small institutions have a greater potential for improvement and change. However, the local branches of the bigger financial institutions should be treated as if they are smaller institutions by auditing the share of their larger parent company’s total business that is attributable to their local neighborhoods! If the main office or the branch is in a urban downtown, then THAT portion of their business related to THAT neighborhood should be THE determining factor. But if their BRANCH office is in a slum neighborhood or a rich suburb then THAT neighborhood should govern as far as CRA regulations and requirements for intensity of focus is concerned.

In other words; “It’s the neighborhood, stupid!” - Duhh !

J. Peter Holsman, founder
The Henry K. Holsman Institute for Advanced Affordable Family Housing Studies