FDIC Federal Register Citations

From: Michael Trend [mailto:MTrend@cityofsanluis.org]
Sent: Wednesday, October 13, 2004 5:15 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

This e-mail is in opposition to the proposed revisions to the Community Reinvestment Act, which would allow banks of "only" $1 billion in assets to be treated as "small banks", and thus, undergo only cursory scrutiny, much like banks of less than $250 million in assets under current rules.

For years, I sat on a CRA committee in Clark County, Nevada, and soon learned that the Community Reinvestment Act was responsible for convincing financial institutions that they should become "good citizens" by serving the entire community, not just its more well-off members. Prior to the enactment of the law, redlining and limiting access of minorities, women, and moderate income individuals were the order of the day.

The City of San Luis is a small border town in Arizona that is 95% Hispanic. Its population is of very low income overall. The services that banks provide under current CRA relations are invaluable in such basics as our first time home buyers programs.

Frankly, were the law to be changed and the threshold of a small bank raised, financial institutions would have but little incentive to serve low- and moderate income members of our community. The proposed changes are banker-oriented and would gut those provisions that have resulted in fair access to credit.

Dr. Michael Trend
Grants Coordinator
City of San Luis
Administrative Services Department
PO Box 1170
San Luis, AZ 85349
Phone: 928.627.2027