Business & Economic Development & Revitalization
Corporation
of Palm Beach County
From: Gainesbedr@aol.com [mailto:Gainesbedr@aol.com]
Sent: Friday, September 17, 2004 12:54 PM
To: Comments
Subject: RIN 3064-AC50
Mr. Robert Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
Dear Mr. Feldman:
As a "CED" (Community Economic Development) practitioner,
I urge you to withdraw your proposed changes to the Community Reinvestment
Act regulations. CRA is the incentive tool for increasing homeownership
and stimulating economic development in Urban and Rural historically
underserved areas. As a critical and rare investment tool, banks
should not be released based upon size of assets to invest and serve
low and moderate-income communities.
In addition eliminating any one of the three activities - community
development lending, investing, and services - will result in even
fewer loans and investments in affordable housing, community health
centers, community centers and economic development projects in lagging
regions.
The elimination of the service test would deal a "death blow" to
responding to the credit needs of low and moderate income consumers
and small businesses because of the lack of data collection which
would result from no longer provide affordable checking and savings
accounts to low income consumers and lending to small businesses.
Without this data the public has no accountability tool for gauging
whether the credit needs of these communities are being served. Your
proposal that community development activities benefit any group
of individuals rather than only low and moderate income individuals
will result in a sharecropping system of predatory and trickle down
community development activities in these communities. Activities
must be targeted to those in greatest need. Otherwise benefits will
be channeled to those with greater influence and access and activities
will benefit those who have over those who do not.
Finally, your proposal is in direct contravention to the mandate
of the CRA to meet community needs. Please consider this request
to withdraw your proposal. Let us jointly (banking and ced community)
develop a path that would expand and not eliminate the tools for
equitable and prosperous community and economic development for historically
underserved persons and communities.
Sincerely,
Lia T. Gaines
President and CEO
Business & Economic Development & Revitalization Corporation
of Palm Beach County
