From: Sheryl Davis [mailto:sbdc@ruraltel.net]
Sent: Wednesday, September 15, 2004 11:55 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
It is important that the requirement for community reinvestment by
banks not be diluted. As banks continue to consolidate, management is
moved from smaller communities to larger ones and the personal
involvement of the bank in its community decreases. Decision making no
longer is influenced by community considerations.
Small businesses are currently being adversely affected by the
movement of loan approval from local district offices to consolidated
locations. Only those who fit a pre determined criteria will be able to
obtain an SBA guarantee, while those with special circumstances, even
though the loan would be viable, will not receive guaranteed funding.
The same thing will happen to smaller communities. We already see it
in the daily activities of our smaller banks that have consolidated.
Without the CRA, I believe we will see even less involvement of these
banks in our communities at a time when rural America needs all the
reinvestment it can get.