From: Todd Harvey [mailto:todd@jubileerestore.org]
Sent: Thursday, September 16, 2004 5:13 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
To Whom it may concern;
Under current rules, small banks with assets under $250 million
undergo a limited CRA exam that covers only some basic lending
activities. Larger banks undergo a full CRA exam that covers lending,
investments, and services. Now the Federal Deposit Insurance Corporation
(FDIC) has proposed to allow all banks with assets under $1 billion to
have the limited exam.
Only 6% of FDIC-regulated banks would face a full CRA exam. This change
would harm low- and moderate-income communities, and leave some states
with no banks subject to a full CRA exam. The Office of Thrift
Supervision (OTS) has already finalized a similar rule. The two other
regulators, the Federal Reserve Board and the Office of the Comptroller
of the Currency, are considering a similar change. Other changes could
also follow.
