FDIC Federal Register Citations

From: NHS@aol.com [mailto:NHS@aol.com]
Sent: Wednesday, October 20, 2004 2:20 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Thank you for the opportunity to comment on the proposed changes regarding changes in CRA requirements for banking institutions. We strongly oppose removing CRA responsibility from smaller institutions. 

The Community Reinvestment Act has been the nation's most successful program of bringing the resources of the market into underserved areas. Many banking institutions who may have been coerced into providing services in certain areas have found profitable markets. This is true of small as well as large institutions. One of NHS of Orange County’s lender partners, a small thrift, actually changed its business plan to focus on providing mortgages to lower income families after a bank executive served on the NHS loan committee and realized that there were many credit-worthy people not being served by local banks. It is unlikely that the executive would have been on the NHS loan committee had it not been for CRA.

Many of the inovative and most successful programs that NHS of Orange County have been in partnership with small and mid-size lenders.

CRA is working. There are improvements that can be and should be made. Reducing the number of institutions covered is not one of them.

Glenn Hayes
Executive Director
Neighborhood Housing Services of Orange County
Changing lives and strengthening neighborhoods -- www.nhsoc.org