From: Channa Grace
Sent: Friday, August 20, 2004 5:59 PM
To: Comments
Subject: Please withdraw the proposed rule to raise the small bank
asset threshold
To Whom It May Concern,
I represent a smaill non-profit affordable housing development
firm and the Community Reinvestment Act is critical to the work
we and others like us throughout this nation undertake on behalf
of persons with modest means. Raising the asset threshold for “small
banks,” which are exempt from the Community Reinvestment
Act’s more stringent exams, will undoubtedly jeopardize the
work that we do by significantly reducing investments in low and
moderate income communities Such a change will mean that many rural
communities and states will not have access to any institutions
required to offer services and investments that benefit low and
moderate income neighborhoods.
Presently, those banks subject to the CRA must demonstrate that
they provide both services and investments that benefit low and
moderate income households and neighborhoods in their communities.
The Community Reinvestment Act is a critical component to the work
we do and our community’s affordable housing and community
development solutions. We oppose any increase to the threshold
of what is considered to be a small bank. The proposed FDIC rule
would exempt many of our community’s critical partners from
the effective and productive requirements currently in place. We
urge FDIC to withdraw its proposed rule.
Sincerely,
Channa Grace
W.O.R.K.S.
1139 West 6th Street
Los Angeles, CA 90017
