FDIC Federal Register Citations

Township of Woodbridge, NJ

From: Bence, Cynthia [mailto:Cynthia.Bence@twp.woodbridge.nj.us]
Sent: Monday, October 18, 2004 3:25 PM
To: Comments
Subject: Re: RIN 3064-AC50

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Re: RIN 3064-AC50

Dear Mr. Feldman:

I am opposed to the watering down of CRA (Community Reinvestment Act)
requirements for mid-sized banks. CRA is vital for increasing homeownership
and economic development in lower-income communities. However, your
proposed changes will halt the progress that has been made.

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
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 few loans and investments in affordable rental
housing, health clinics, community centers and economic development
projects.

In the watered-down exam, you would allow mid-sized banks to 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.

You also propose that community development activities in rural areas should
benefit any group of individuals instead of only low-and-moderate-income
individuals. But this will allow banks to cherry-pick and focus on affluent
residents in rural areas rather than the lower income consumers CRA targets.
Finally, you would also eliminate publicly available data on the small
business lending of mid-sized banks. Without data, community groups and
citizens cannot hold banks accountable for lending to small businesses in
their neighborhoods.

Your changes directly oppose CRA's mandate to require lenders to meet
community needs. CRA is too important to be gutted. Please drop your
proposal like the two other federal agencies that recognized its harm to
underserved communities.

Sincerely,

Frank G. Pelzman, Mayor
Township of Woodbridge
One Main Street
Woodbridge, NJ