FDIC Federal Register Citations

From: Jane Zhang [mailto:JZhang@accion.org]
Sent: Wednesday, October 20, 2004 10:00 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Dear Sir or Madam,
Under current rules, small banks with assets under $250 million undergo a limited CRA exam that covers only some basic lending activities. Larger banks undergo a full CRA exam that covers lending, investments, and services. Now the Federal Deposit Insurance Corporation (FDIC) has proposed to allow all banks with assets under $1 billion to have the limited exam. Only 4% of FDIC-regulated banks would face a full CRA exam. This change would harm low- and moderate-income communities, and leave some states with no banks subject to a full CRA exam. The Office of Thrift Supervision (OTS) has already finalized a similar rule. The two other regulators, the Federal Reserve Board and the Office of the Comptroller of the Currency, are considering a similar change. Other similar organization could also follow in this example. Accion USA is a non-profit, small business lender serving low-income communities in 3 states - Florida, Georgia, and Massachusetts. We have loaned over $90 million to more than 10,000 clients as of year-end 2003. Currently, the Miami branch has 190 clients with a portfolio of $650K. The CRA exam requirement is a major incentive for banks in the communities we serve to partner with us in supporting our lending services, either through providing direct loan funds, or by referring clients to us that they are unable to serve. We at the Miami branch of Accion USA believe that removing the full CRA requirements for banks with assets above $250 million would discourage banks from participating in our partnership opportunities. Please reconsider the adoption of this policy.
Respectfully yours,
Luz Gomez
Program Director
Accion USA, Miami