FDIC Federal Register Citations

From: mocasio@cdcloans.com [mailto:mocasio@cdcloans.com]
Sent: Monday, October 18, 2004 12:25 AM
To: Comments
Subject: Save the Community Reinvestment Act

Mr. Feldman:

I am a concerned operator of a community development corporation (CDC) who opposes your rule proposal that would ease Community Reinvestment Act (CRA) requirements for most of the banks in my regiom. CRA is vital for promoting minority business ownership, home ownership and meeting the needs of struggling communities in this region plus support the capital requirements of CDFIs and nonprofit organizations.

The proposed Federal Deposit Insurance Corporation (FDIC) rule is disconcerning and would be harmful to the communities in which we operate providing much-needed capital to women and minority-owned business enterprises.

In the new watered-down process for mid-size banks, FDIC would allow these financial institutions to pick and choose which community development activities they will undertake. 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. That will mean fewer jobs, fewer homes and fewer community services. What is your rationale behind this?

The Community Reinvestment Act was made law to require lenders to meet community needs. Your rule proposal flies directly in the face of this requirement. It would harm our communities, the quality of life and the many CDCs across the nation who rely upon these large financial institutions to serve as our partners to strengthen distressed communities making them better places to live and work.

I urge you in the strongest possible terms to drop this hurtful rule proposal.

Michael Ocasio
1650 Iowa Avenue
Suite 150
Riverside, CA 92507