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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

The Council of The City of New York

October 20, 2004

Mr. Robert E. Feldman, Executive Secretary
Attn: Comments/Legal ESS, Federal Deposit Insurance Corp.
550 17th Street, NW
Washington, D.C. 20429
RIN 3064-AC50
comments@FDIC.gov

Dear Mr. Feldman:

We wish to declare our opposition to the proposed revisions to 12CFRpart 345 implementing the Community Reinvestment Act (CRA) (69FR 51611 August 20, 2004).

It is our understanding that these revisions would, in effect, change the definition of “small banks” by raising the asset threshold for these banks from $250.0 million to $1.0 billion, regardless of the bank’s affiliation with another financial institution. Presently, “small banks” with assets under $250.0 million are exempt from strict compliance with regulations of the Act. With the proposed revisions, a larger number of so- called “small banks” would fall under weaker regulations.

These changes would result in a less stringent examination of these smaller banks’ participation in the Community Reinvestment Act; thus reducing their effective contributions to the development of the communities they serve. It is also our understanding that broader criteria for community development would be established for these “small banks” that could also reduce their role in aiding vitally needed projects.

We are asking, therefore, that our comments are given every positive consideration before the F.D.I.C. makes its decision.

Sincerely,

LEROY COMRIE MIGUEL MARTINEZ
Majority Whip 10th Council District
27th Council District Manhattan
Queens

DAVID I. WEPRIN MELINDA KATZ
23rd Council District 29th Council District
Queens Queens

ROBERT JACKSON ALAN GERSON
7th Council District 1st Council District
Manhattan Manhattan

JOHN C. LIU LARRY B.SEABROOK
20th Council District 12th Council District
Queens The Bronx

YVETTE D. CLARKE DIANA REYNA
40th Council District 34th Council District
Brooklyn Brooklyn

JAMES GENNARO
24th Council District
Queens

THE COUNCIL Of The City of New York
City Hall
New York, N.Y.10007
212-788-7084


Last Updated 11/11/2004 regs@fdic.gov

Last Updated: August 4, 2024