From: Chatfield7@aol.com [mailto:Chatfield7@aol.com]
Sent: Monday, September 13, 2004 11:48 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
Thank you for the opportunity to submit comments on the proposed
rule change. I am strongly opposed to the adoption of this proposed
rule. The revision would significantly reduce the amount of CRA funds
available for affordable housing production in the state of Arizona.
I have read the comments of a number of bankers who complain about "unnecessary
regulation" and the "burden" on smaller banks. During
nearly 20 years of urban planning work in the Southwest, I've seen
the CRA provide significant stimulus to revitalize communities.
We are often able to do so with funds from the smaller community
banks because the big players divert their funds to larger population
centers.
I believe in the power of the marketplace, but the banking industry
has demonstrated that it needs this kind of oversight to ensure
equal access to capital across the community. In areas of my community
where the major banks have closed branches (leaving residents to
check cashing services and payday loan sharks), the only real access
to affordable capital is through CRA programs. And these are largely
through small, local banks.
We've known that a proposal like this would come down the pike,
because the banking industry has long complained about these requirements.
But, in the name of fairness and community health, I implore you
to reject this proposal.
Respectfully submitted,
Don Chatfield, Ph.D.
Tucson, Arizona
