FDIC Federal Register Citations

From: Ruxana Lotia [mailto:RLotia@HAFresno.org]
Sent: Friday, October 15, 2004 9:03 PM
To: Comments
Subject: RIN 3064-AC50

It is imperative that the we do not increase the threshold for financial institutions to undergo the comprehensive CRA examination.

Our current administration is promoting homeownership to minorities but at the same time FDIC is giving more flexibility to financial institutions to balance their community lending investing and service activities based on opportunities in the market and the banks own strategic strengths. We currently have an acute shortage of mortgage products that can benefit low to very low income families and the underwriting methods are very stringent. This rule, if passed will give more flexibility to the banking institutions to limit opportunities they provide to the less fortunate in the community.

CRA monies distributed as donations to non-profits have historically assisted non-profits to provide extensive financial literacy to low to very low income families so that they may establish good credit and aspire to be homeowners. Grass root programs such as Family Self-Sufficiency Fresno Program provide budgeting and financial literacy workshops to over 2,000 families and depend on the CRA funds to assist in meeting the costs. CRA funds also pay for other services and educational workshops to youth and adults.

The very basic requirements for banking industry to reinvest in the communities that support and patronize their business, should be enhanced and not given the flexibility to provide only those services as they seem fit for their strategic gains. This rule will give an opportunity to the financial institutions in fulfilling the credit needs of the fortunate rich in our communities and moving away from servicing all segments of the population including low to very low income families.

Building our community, one family at a time.
Ruxana Lotia
Assisted Housing Manager
Housing Options Division
Fresno Housing Authorities