FDIC Federal Register Citations

From: Cindy Daley [mailto:cindy@rhls.org]
Sent: Wednesday, October 20, 2004 4:31 PM
To: Comments
Subject: Community Reinvestment -- 12 CFR part 345

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-AC50

Dear Mr. Feldman:

I am writing as a concerned citizen who has worked in the field of community development for 25 years. I oppose the proposed regulations. I have seen communities grow by building working relationships with local lending institutions, with the obvious benefit of greater investment in the communities. The Community Reinvestment Act has been a key factor in prompting this investment.

The proposed regulations will remove the motivation for many smaller institutions to invest in their communities, especially in low and moderate income communities. Investments in small loans to low income families and small entrepreneurs may not be very profitable for the institution, but they can be life transforming for the borrowers.

Under the proposed regulations, only 6.5% of FDIC regulated institutions would be required to report CRA activities. While this may in fact cover institutions with 85% of all assets, the large institutions do not cover all areas. Rural communities will be particularly hard hit. In Pennsylvania, 44 banking institutions will be exempt from filing reports.

Moreover, in rural communities, banks would no longer need to invest in low and moderate income loans in order to receive favorable CRA ratings. This will leave a large lending void in those communities.

CRA is working. Please withdraw the proposed regulations and let CRA continue to work for stronger communities.

Sincerely,

Cynthia Witman Daley