FDIC Federal Register Citations

September 10, 2004

Thomas J. Curry, Director
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Dear Mr. Curry:

Systemic, substantial and grave are words that describe my concern over OTS's announcement to reduce three-part CRA examinations. The chilling effect this choice may impose on services and financial support for community development work in distressed areas will be deepened if you elect to follow this course.

This proposed lower CRA standard will diminish the innovation, asset base and scope of services built in reliance of CRA standards. Removing tests and their resulting obligations within CRA will stifle the growth of CDFI's and CDC's working to serve low income people who build and provide affordable homes. This systemic change will stifle the streams of incentives which support revitalization in distressed urban centers and within faltering rural economies.

Combined with the effects of weakened government support for revitalization, we see deepening divides between the asset poor and the asset rich. Some non-profits report that as many as 75-80% of their bank investors will be de-regulated as a result of OTS's choice.

Deregulation has its place and purpose; it is not here and not now!

Sincerely,

Carol N. Maria
Executive Director
Urban Economic Development Assoc of Wisconsin
Milwaukee, WI