FDIC Federal Register Citations

To the FDIC:

I urge that you withdraw the proposed changes to the Community Reinvestment Act (CRA) regulations. I believe that people must be permitted access to information about the lending practices and patterns of the financial institutions in their communities that seek their business.

CRA has been an effective financial vehicle for rural and urban communities for decades. Low and moderate income families of all races and ethnicities have benefited from CRA with increased opportunities to purchase homes, open small businesses, or operate farms. The success of local communities gaining access to private capital should not be jeopardized. The proposed changes will dramatically reduce the ability of communities to monitor and promote community reinvestment.

Currently, banks with assets of at least $250 million are rated by performance evaluations that scrutinize their level of lending, investing, and services within low- and moderate-income communities. The proposed changes would substitute a less challenging criterion of community development for state-charted banks with assets between $250 million and $1 billion. This proposal would allow mid-size banks to choose a loosely defined “community development activity” rather than the current requirement of providing comprehensive community development activities needed by low- and moderate-income communities.

Many believe, and we fear, that the proposed community development criterion could result in fewer loans and a significant reduction in affordable rental housing investments. Community service facilities and economic development projects would falter from lack of financial support, as mid-size banks no longer maintain or build branches in low- and moderate-income communities. Families in these communities would lose access to affordable banking services.

Sincerely,
Tom Cordaro
1450 Green Trails Dr
Naperville, IL 60540