Mr. Robert E. Feldman Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-ACSO
Dear Mr. Feldman:
Please do not allow the proposed changes to the CRA regulations to
become law.Your 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; watering down CRA (Community Reinvestment Act) requirements
for mid-sized banks. CRA is vital for increasing homeownership and
economic development in lower-income communities.
Right now, these banks must make community development loans,
investments, and services. Your proposed test allows banks to choose
only one of the three activities. The result will be less community
development activity.
You also propose that community development activities in rural areas
should benefit any group of individuals instead of only low- and
moderate-income individuals. But this will allow banks to cherry-pick
and focus. on affluent residents of rural areas rather than the lower
income consumers CRA targets.
Finally, you 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.
Your changes directly oppose CRA's mandate to require lenders to meet
community needs. CRA is too important to be gutted. Please drop your
proposal like the two other federal agencies that recognized its harm to
underserved communities.
Sincerely,
John Kane
Mary Kane
10235 S. Oakley Ave
Chicago, IL 60643
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