Society of Jesus, N.Y. Province
From: Hallinan, Rev. Mark, S.J.
Sent: Monday, August 23, 2004 11:33 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
I am writing to
urge the FDIC to withdraw its proposed rule raising the asset threshold
for “small banks” from
$250 million to $1 billion and thus exempting these banks from the
more stringent
requirements of the Community Reinvestment Act (CRA).
This change would have a devastating impact on investments in low
and moderate income communities, particularly in rural areas where
institutions with assets of $250 million to $1 billion hold the principal
market share. At a time when affordable housing is vitally needed,
and financing for community development proposals is critical, this
is not the time to exempt banking institutions from compliance with
the terms of the CRA.
Please withdraw this proposed rule change.
Mark Hallinan, S.J.
Asst. for Social Ministries
Society of Jesus, N.Y. Province
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