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VOLUNTEERS OF AMERICA
Michigan
September 20, 2004
Mr. Robert E. Feldman,
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
RE: BIN 3064-AC50
Dear Mr. Feldman:
At Volunteers of America we have a program to build and remodel homes
for low to moderate income people. We also run homeless shelters
providing 35,000 bed-nights of emergency and transitional shelter per
year. Our banks routinely discuss CRA credit as their incentive to
finance our projects. These loans are often low margin for the banks and
the CRA is vital to sustain homeownership and economic development in
lower-income communities.
I understand that banks with over $250 million in assets must be
tested on their number of loans, investments, and services to low and
moderate-income communities. But 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.
In Michigan, the FDIC oversees 107 institutions, controlling $31
billion in assets. Overall, 93% have under $1 billion in assets and 22%
have between $250 million and $1 billion in assets and would be affected
by the proposed changes in CRA regulations. Eighty nine percent of the
institutions in urban areas have less than $ I billion in assets. If the
proposed changes to CRA are adopted by the FDIC, 46% of the assets in
urban Michigan would not be subject to the current level of scrutiny
under CRA. I'm further concerned that accountability would be lost due
to dropping public reporting under the act.
Your changes directly oppose CRA's mandate to require lenders to meet
community needs. CRA progress is too important to be cut back. I urge
you to reconsider your proposal.
Sincerely,
Patrick Patterson
Director of Operations
Volunteers of America
Lansing, MI
cc: Michigan Community Reinvestment Coalition
National Community Reinvestment Coalition
Senator Carl Levin
Senator Debbie Stebenow
Representative Mike Rogers |
