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FDIC Federal Register Citations

February 13, 2003

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/ES
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC 20429

Re: Proposed Rule Part 303

Dear Mr. Feldman:

I am writing to express concerns with the FDCI's proposal to waive regulatory procedures on a case-by-case basis that are not required by statute. Woodstock Institute, founded in 1973, is a nationally-recognized resource on the credit and capital needs of low-income and minority communities. The Institute engages in applied research, policy development, and technical assistance to promote community economic development.

If the FDIC waived regulations not required by statute, I believe that it is likely that the agency will waive public comment, public notice requirements, and other vital parts of the merger application process. Consequently, the public's input into mergers that affect access to credit and capital for minority and low- and moderate-communities will be cut-off. In other words, the public would have no recourse to a federal agency when a merger affects the wellbeing of their community. Public comments have motivated banks and federal agencies to address weaknesses in lender community reinvestment and fair lending performance. Therefore, eliminating public comment eliminates the chance to increase bank lending and investing after mergers.

In order for a regulatory process to be fair to all parties, the federal agency cannot waive a process for some banks and not others. Waivers on a case-by-case basis are arbitrary and result in uneven regulatory enforcement. I urge the FDIC to withdraw this proposal. The FDIC would be abdicating its fair lending and community reinvestment enforcement obligations if it adopted the same non-statutory waiver procedures as the OTS.

Sincerely,

Marva E. Williams
Senior Vice President
Woodstock Institute
407 South Dearborn Ave., Suite 550
Chicago, Il  60605

MEW/bab

Last Updated 03/10/2003 regs@fdic.gov

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