From: Georgia Mjartan [mailto:georgia@kenhubbell.com]
Sent: Monday, September 13, 2004 6:59 PM
To: Comments
Cc: 'Ken Hubbell'; 'Ed Sivak'
Subject: We oppose changes to Community Reinvestment Act (3064-AC50)
I’m writing
on behalf of Ken Hubbell and Associates, a consulting firm (of
which I am
a part) that works with many nonprofits and community
development groups in rural areas. Our organization opposes the FDIC
proposal to weaken the Community Reinvestment Act. We are concerned
that rural areas will be hardest hit by this proposal to raise the
asset level for CRA examinations to $1 billion. If this proposal
were passed, 97.7% of all rural banks in the Mid-South would not
be subject to the more rigorous CRA examinations. That would be unfortunate,
as these examinations provide an incentive for rural banks to engage
in community reinvestment.
We also oppose the FDIC proposal to expand the definition of rural
community reinvestment from investments in low-income individuals
to investments in anyone residing in a rural area. We fear that investments
that once would have been made to low-income individuals thanks to
incentives provided by the Community Reinvestment Act would, under
this proposal, be made to wealthy rural residents instead.
We hope you will consider these comments.
Thank you,
Georgia Mjartan, Project Manager
Ken Hubbell & Associates
401 West Capitol Ave, Ste. 702
Little Rock, AR 72201
