From: kayzar [mailto:kayzar@cox.net]
Sent: Thursday, September 16, 2004 7:48 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
I worked in banking and mortgage finance for many years and am now
teaching and conducting research about urban issues. It has been
my experience that the CRA works as an incentive for banks to invest
in their local community. I fear that a 'relaxation' of the oversight
for many banks with regard to the CRA will reduce this incentive.
Drs. Ford and Griffin from San Diego State demonstrated the ill effects
of redlining on inner-city communities in the San Diego and Columbus,
Ohio area in their research during the 1970s and 1980s. Can we really
afford to let banks 'choose to overlook' older or lower-income communities
once again because they are no longer held to a higher standard by
intensive CRA audits? Since it has been demonstrated as a problem
in the past, I question the logic for this 'relaxation' of oversight.
Is it simply because costs can be lowered if fewer banks are subject
to the more intensive audit? I hope that this change will not come
to pass-for the sake of the populations that benefit from such community
reinvestment programs as those that target 'low-income homebuyers'
as beneficiaries. Sincerely, Brenda Kayzar
********************
Brenda Kayzar
Department of Geography
San Diego State University
