FDIC Federal Register Citations

From: Wilds, Karen R. [mailto:kwilds@nnrha.org]
Sent: Friday, October 15, 2004 4:02 PM
To: Comments
Cc: cra@nahro.org
Subject: "RIN 3064-AC50"

I oppose the proposal from the FDIC which threatens to undermine the Community Reinvestment Act (CRA), enacted in 1977 to prevent redlining and to encourage banks and thrifts to help meet the credit needs of all segments of their communities, including low- and moderate-income neighborhoods.

The proposed new rule would:

* Raise the asset threshold from $250 million to $1 billion of financial institutions that have to undergo the comprehensive CRA examination.

* Add language allowing banks to "balance their community lending investing and service activities based on opportunities in the market and the banks own strategic strengths"

These modifications not only decrease the number of banks that would face the comprehensive compliance exams, but would also affect the examination itself by removing the requirements on the investment and service elements and instead making them options under the lending test.

These changes will have the effect of discouraging the participation of banks in community development activities.

Karen Wilds , Exec. Director, Newport News VA Redevelopment & Housing Authority 757-928-2620
PO Box 757, Newport News VA 23607